Table of Contents

Lower West Fork Project Final EIS ii-1

TABLE OF CONTENTS

SUMMARY .................................................................................................................................................... i

INTRODUCTION ..............................................................................................................................................................I

PROPOSED ACTION ........................................................................................................................................................I

PURPOSE AND NEED FOR ACTION ..................................................................................................................................I

PUBLIC INVOLVEMENT AND ISSUES ..............................................................................................................................II

Issues........................................................................................................................................................................ii

ALTERNATIVES CONSIDERED IN DETAIL......................................................................................................................III

Alternative 1 (No Action)....................................................................................................................................... iii

Alternative 2 (Proposed Action)............................................................................................................................. iii

Alternative 3............................................................................................................................................................iv

SUMMARY OF EFFECTS ............................................................................................................................................... IV

Vegetation ...............................................................................................................................................................iv

Fire and Fuels.......................................................................................................................................................... v

Air Quality ............................................................................................................................................................... v

Soils.........................................................................................................................................................................vi

Watershed ...............................................................................................................................................................vi

Fisheries.................................................................................................................................................................vii

Wildlife...................................................................................................................................................................vii

Noxious Weeds......................................................................................................................................................viii

Threatened, Endangered, and Sensitive Plant Species .........................................................................................viii

Heritage ................................................................................................................................................................viii

Recreation, Roadless, and Wilderness....................................................................................................................ix

Economics...............................................................................................................................................................ix

Visual Resources...................................................................................................................................................... x

Human Health and Herbicide Use..........................................................................................................................xi

PREFERRED ALTERNATIVE......................................................................................................................................... XI

SUMMARY OF CHANGES BETWEEN THE DRAFT AND FINAL EIS ............................................. i

CHAPTER 1.....................................................................................................................................................................I

CHAPTER 2.....................................................................................................................................................................I

CHAPTER 3.....................................................................................................................................................................I

CHAPTER 4....................................................................................................................................................................II

APPENDIX A..................................................................................................................................................................II

APPENDIX B..................................................................................................................................................................II

APPENDIX C.................................................................................................................................................................III

APPENDIX D.................................................................................................................................................................III

APPENDIX E.................................................................................................................................................................III

APPENDIX F .................................................................................................................................................................III

CHAPTER 1.0

PURPOSE AND NEED

1.1 INTRODUCTION ......................................................................................................................................1

1.2 PROPOSED ACTION ................................................................................................................................1

1.3 PURPOSE..................................................................................................................................................2

1.4 NEED........................................................................................................................................................4

1.4.1 REDUCE FUEL LOADS AND LOWER CROWN FIRE HAZARD IN LOW ELEVATION PONDEROSA PINE/DOUGLAS-FIR 

FORESTS........................................................................................................................................................................4

A. Current Condition ..............................................................................................................................................4

B. Desired Conditions.............................................................................................................................................5
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ii-2 Lower West Fork Project Final EIS 

1.4.2 IMPROVE FOREST RESILIENCE TO NATURAL DISTURBANCES (FIRE, INSECTS, DISEASE), PARTICULARLY THE 

HEALTH AND RESILIENCE OF LARGE DIAMETER (>21” DBH) PONDEROSA PINE TREES;.................................................. 6

A. Current Condition.............................................................................................................................................. 6

B. Desired Conditions ............................................................................................................................................ 6

1.4.3 MAINTAIN OR INCREASE SHADE INTOLERANT SPECIES....................................................................................... 6

A. Current Condition.............................................................................................................................................. 6

B. Desired Conditions ............................................................................................................................................ 7

1.4.4 IMPROVE OVERALL SOIL, WATERSHED, AND FISHERIES CONDITIONS BY REDUCING ROAD IMPACTS AND 

RESTORING SOILS ON TERRACED LANDS IN THE AREA................................................................................................... 7

A. Current Condition.............................................................................................................................................. 7

B. Desired Conditions ............................................................................................................................................ 8

1.5 MEASURES Of SUCCESS ........................................................................................................................ 8

1.6 FOREST PLAN MANAGEMENT AREAS ................................................................................................. 9

1.7 SITE-SPECIFIC FOREST PLAN AMENDMENT ..................................................................................... 10

A. Winter Range Thermal Cover .........................................................................................................................10

B. Elk Habitat Effectiveness................................................................................................................................10

C. Coarse Woody Debris.....................................................................................................................................12

1.8 PROJECT SCOPE ................................................................................................................................... 13

1.8.1 GEOGRAPHIC, TEMPORAL, AND ADMINISTRATIVE SCOPE................................................................................13

1.8.2 DECISION TO BE MADE....................................................................................................................................14

1.8.3 FEIS ORGANIZATION.......................................................................................................................................14

CHAPTER 2.0

ALTERNATIVES

2.1 INTRODUCTION...................................................................................................................................... 1

2.2 ALTERNATIVE DEVELOPMENT AND DESCRIPTIONS......................................................................... 1

2.2.1 PUBLIC PARTICIPATION ...................................................................................................................................... 1

2.2.2 ISSUES................................................................................................................................................................. 3

A. Alternative Development Process...................................................................................................................... 4

B. Alternatives Considered In Detail...................................................................................................................... 5

2.2.3 ALTERNATIVE 1 (NO ACTION)............................................................................................................................ 5

2.2.4 ALTERNATIVE 2 (PROPOSED ACTION)................................................................................................................. 5

2.2.5 ALTERNATIVE 3 ................................................................................................................................................12

2.2.6 COMPARISON OF ALTERNATIVES .....................................................................................................................15

2.2.7 ALTERNATIVES CONSIDERED BUT ELIMINATED................................................................................................16

2.3 MITIGATION MEASURES AND PROJECT DESIGN.............................................................................. 18

2.3.1 MONITORING ....................................................................................................................................................25

2.4 COMPARISON OF EFFECTS BETWEEN ALTERNATIVES ..................................................................... 26

CHAPTER 3.0

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

3.1 INTRODUCTION ................................................................................................................................... 1

 3.1.1 ENVIRONMENTAL CONSEQUENCES ANALYSIS................................................................................... 2

3.2 VEGETATION ...................................................................................................................................... 1

3.2.1 SCOPE OF ANALYSIS AND ANALYSIS METHODS .............................................................................................. 1
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Lower West Fork Project Final EIS ii-3

A. Analysis Area.....................................................................................................................................................1

B. Stand Diagnosis.................................................................................................................................................1

3.2.2 REGULATORY FRAMEWORK.........................................................................................................................3

A. National Forest Management Act......................................................................................................................3

B. Bitterroot National Forest Plan Direction ........................................................................................................5

3.2.3 AFFECTED ENVIRONMENT................................................................................................................................5

A. Existing Condition of Forest Structure and Composition..................................................................................5

B. Desired Stand Conditions................................................................................................................................ 17

3.2.4 ENVIRONMENTAL CONSEQUENCES................................................................................................................ 20

A. Effects Common to All Alternatives................................................................................................................. 20

B. Effects Common to Action Alternatives........................................................................................................... 20

C. Alternative 1 (No Action) ................................................................................................................................ 25

D. Alternative 2 (Proposed Action)...................................................................................................................... 26

E. Alternative 3 .................................................................................................................................................... 31

F. Cumulative Effects........................................................................................................................................... 32

3.2.5 CONSISTENCY WITH LAWS, REGULATIONS AND THE FOREST PLAN .............................................................. 37

3.3 FIRE And FUELS.......................................................................................................................................1

3.3.1 SCOPE OF ANALYSIS AND ANALYSIS METHODS................................................................................................1

A. Area of Analysis...............................................................................................................................................1

B. Analysis Methods..............................................................................................................................................1

3.3.2 REGULATORY FRAMEWORK ..............................................................................................................................3

A. National Guidance............................................................................................................................................3

B. Local Guidance ................................................................................................................................................4

3.3.3 AFFECTED ENVIRONMENT..................................................................................................................................6

A. Fire Groups and Fire Regimes...........................................................................................................................6

B. Current Fire Behavior Conditions......................................................................................................................8

C. Wildland Urban Interface (WUI) - FMU-1 ..................................................................................................... 12

3.3.4 ENVIRONMENTAL CONSEQUENCES................................................................................................................... 14

A. Direct and Indirect Effects ............................................................................................................................... 14

B. Cumulative Effects............................................................................................................................................ 18

3.3.5 CONSISTENCY WITH FOREST PLAN, LAWS, AND REGULATIONS ........................................................................ 22

3.4 AIR QUALITY ..........................................................................................................................................1

3.4.1 SCOPE OF ANALYSIS AND ANALYSIS METHODS ..................................................................................................1

A. Area of Analysis..................................................................................................................................................1

B. Analysis Methods................................................................................................................................................2

3.4.2 REGULATORY FRAMEWORK ...............................................................................................................................4

A. National Guidance..............................................................................................................................................4

B. State Guidance...................................................................................................................................................5

C. Local Guidance ..................................................................................................................................................5

3.4.3 AFFECTED ENVIRONMENT..................................................................................................................................5

A. Air Quality ..........................................................................................................................................................5

3.4.4 ENVIRONMENTAL CONSEQUENCES.....................................................................................................................6

A. Direct and Indirect Effects..................................................................................................................................6

B. Cumulative Effects........................................................................................................................................... 11

3.4.5 CONSISTENCY WITH BITTERROOT FOREST PLAN AND OTHER REGULATORY DIRECTION ................................ 13
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ii-4 Lower West Fork Project Final EIS 

3.5 SOILS .................................................................................................................................................. 1

3.5.1 SCOPE OF ANALYSIS AND ANALYSIS METHODS............................................................................................... 1

A. Assessment of Existing Soil Condition and Detrimental Soil Disturbance (DSD).......................................... 1

3.5.2 REGULATORY FRAMEWORK............................................................................................................................. 1

3.5.3 AFFECTED ENVIRONMENT ............................................................................................................................... 2

A. Soil Characteristics, Potentials, and Limitations to Management.................................................................. 2

B. Site Conditions in Treatment Areas ................................................................................................................ 5

C. Other Effects on Existing Soil Condition in the Project Area.......................................................................... 6

3.5.4 ENVIRONMENTAL CONSEQUENCES ................................................................................................................11

A. Direct and Indirect Effects for Alternative 1 – No Action.............................................................................11

B. Direct and Indirect Effects for Alternatives 2 and 3 .....................................................................................14

C. Cumulative Effects for All Alternatives.........................................................................................................36

3.5.5 REGULATORY FRAMEWORK AND CONSISTENCY ............................................................................................45

A. Region 1 Soil Quality Standards and Region 1 Supplement 2500-99-1........................................................45

B. Forest Plan Management Direction..............................................................................................................45

C. National Forest Management Act.................................................................................................................46

D. Monitoring....................................................................................................................................................46

3.6 WATERSHED........................................................................................................................................... 1

3.6.1 INTRODUCTION................................................................................................................................................. 1

3.6.2 REGULATORY FRAMEWORK ............................................................................................................................. 1

A. Forest Plan Direction ..................................................................................................................................... 1

B. Montana Streamside Management Zone Act................................................................................................... 1

C. Montana State Water Quality Standards........................................................................................................ 1

D. Clean Water Act ............................................................................................................................................. 1

3.6.3 ANALYSIS AREA AND ANALYSIS METHODS ..................................................................................................... 2

A. Stream Sedimentation ..................................................................................................................................... 4

B. Water Yield....................................................................................................................................................... 5

C. Channel Conditions......................................................................................................................................... 5

D. Herbicides........................................................................................................................................................ 6

3.6.4 AFFECTED ENVIRONMENT................................................................................................................................ 6

A. Existing Sediment Sources.............................................................................................................................. 6

B. Existing Stream Conditions............................................................................................................................. 8

3.6.5 ENVIRONMENTAL CONSEQUENCES.................................................................................................................16

A. Effects Common to Alternatives 2 and 3 ....................................................................................................... 16

B. Direct and Indirect Effects............................................................................................................................19

C. Cumulative Effects......................................................................................................................................... 35

3.6.6 CONSISTENCY WITH THE BITTERROOT FOREST PLAN AND OTHER REGULATORY DIRECTION........................41

A. Bitterroot National Forest Plan.....................................................................................................................41

B. Montana State Regulation.............................................................................................................................. 43

C. Clean Water Act............................................................................................................................................. 44

D. Executive Order No. 11988 and 11990, Floodplain and Wetland Protection............................................... 45

3.7 FISHERIES ............................................................................................................................................. 1

3.7.1 INTRODUCTION................................................................................................................................................. 1

3.7.2 REGULATORY FRAMEWORK ............................................................................................................................. 1

3.7.3 AREA OF ANALYSIS.......................................................................................................................................... 1

3.7.4 ANALYSIS METHODS........................................................................................................................................ 2

3.7.5 EXISTING CONDITION....................................................................................................................................... 2

A. Fish Populations............................................................................................................................................. 2
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Lower West Fork Project Final EIS ii-5

B. Fish Habitat.....................................................................................................................................................6

C. INFISH Riparian Management Objectives (RMOs)........................................................................................7

D. Sediment....................................................................................................................................................... 10

3.7.6 ENVIRONMENTAL CONSEQUENCES.................................................................................................................. 11

A. Direct and Indirect Effects............................................................................................................................ 11

B. Cumulative Effects........................................................................................................................................ 30

C. Fisheries Biological Evaluation ................................................................................................................... 32

3.7.7 CONSISTENCY WITH THE BITTERROOT FOREST PLAN AND OTHER REGULATORY DIRECTION........................... 34

3.8 WILDLIFE.............................................................................................................................................1

3.8.1 INTRODUCTION .................................................................................................................................................1

3.8.2 REGULATORY FRAMEWORK..............................................................................................................................1

A. Endangered Species Act of 1973 (as amended)...............................................................................................1

B. National Forest Management Act of 1976.......................................................................................................1

C. Bitterroot National Forest Plan (Forest Plan)................................................................................................1

3.8.3 AREA OF ANALYSIS ..........................................................................................................................................1

3.8.4 EFFECTS ANALYSIS METHODS ..........................................................................................................................2

3.8.5 AFFECTED ENVIRONMENT AND EFFECTS TO WILDLIFE.....................................................................................2

A. Old Growth Habitat.........................................................................................................................................2

B. Snags ............................................................................................................................................................ 11

C. Elk (Cervus elaphus) (Management Indicator Species) ............................................................................... 14

D. American Marten (Martes americana) (Management Indicator) & Fisher (Martes pennanti) (Sensitive).. 28

E. Pileated Woodpecker (Dryocopus pileatus) (Management Indicator)......................................................... 35

F. Gray Wolf (Canis lupis) (Non-Essential, Experimental Population)............................................................ 41

G. Canada Lynx (Lynx Canadensis) (Threatened)............................................................................................. 43

H. Bald Eagle (Haliaeetus leucocephalus) (Sensitive) ...................................................................................... 45

I. Western Big-Eared Bat (Plecotus townsendii) (Sensitive)............................................................................. 46

J. Wolverine (Gulo gulo) (Sensitive)................................................................................................................. 47

K. Boreal Toad (Bufo boreas) (Sensitive)......................................................................................................... 48

L. Flammulated Owl (Otus flammeolus) (Sensitive) ......................................................................................... 52

M. Black-backed Woodpecker (Sensitive).......................................................................................................... 58

N. Forest Land Birds......................................................................................................................................... 61

O. Animal Movement, Migration & Dispersal................................................................................................... 63

3.8.6 CONSISTENCY WITH BITTERROOT FOREST PLAN AND OTHER REGULATORY DIRECTION .............................. 65

A. Habitat.......................................................................................................................................................... 65

B. Management Indicator Species..................................................................................................................... 65

C. Threatened and Endangered Species ........................................................................................................... 66

D. Sensitive Species........................................................................................................................................... 66

E. Other............................................................................................................................................................. 66

3.8.7 BIOLOGICAL ASSESSMENT/EVALUATION FOR THREATENED, ENDANGERED AND SENSITIVE SPECIES ........... 68

3.9 NOXIOUS WEEDS..................................................................................................................................1

3.9.1 INTRODUCTION .................................................................................................................................................1

3.9.2 REGULATORY FRAMEWORK..............................................................................................................................1

3.9.3 AREA OF ANALYSIS ..........................................................................................................................................2

3.9.4 EFFECTS ANALYSIS METHODS ..........................................................................................................................2

3.9.5 EXISTING CONDITION .......................................................................................................................................2

A. Species Information ........................................................................................................................................ 3

3.9.6 ENVIRONMENTAL CONSEQUENCES ...................................................................................................................5

A. Effects Common to All Alternatives................................................................................................................. 5
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ii-6 Lower West Fork Project Final EIS 

B. Direct and Indirect Effect................................................................................................................................. 6

C. Cumulative Effects.........................................................................................................................................11

3.9.7 CONSISTENCY WITH THE FOREST PLAN AND OTHER REGULATIONS ..................................................................11

3.10 THREATENED, ENDANGERED, AND SENSITIVE PLANT SPECIES.................................................... 1

3.10.1 INTRODUCTION ................................................................................................................................................ 1

3.10.2 REGULATORY FRAMEWORK............................................................................................................................. 1

3.10.3 AREA OF ANALYSIS ......................................................................................................................................... 1

3.10.4 EFFECTS ANALYSIS METHODS ........................................................................................................................ 1

3.10.5 EXISTING CONDITION....................................................................................................................................... 2

A. Dwarf Onion (Allium parvum).......................................................................................................................... 2

B. Rocky Mountain paintbrush (Castilleja covilleana) ......................................................................................... 3

C. Lemhi penstemon (Penstemon lemhiensis) ....................................................................................................... 3

D. Sensitive Plant Habitat ..................................................................................................................................... 4

E. Species of Potential Concern ............................................................................................................................ 4

F. Species of Interest ............................................................................................................................................. 4

G. Sensitive Plant Species Excluded from Analysis............................................................................................... 4

H. Boulder Creek Research Natural Area............................................................................................................. 4

3.10.6 ENVIRONMENTAL CONSEQUENCES .................................................................................................................. 5

A. Effects Common to All Action Alternatives..................................................................................................... 5

B. Direct and Indirect Effects.............................................................................................................................. 7

C. Cumulative Effects........................................................................................................................................12

D. Determination of Effects for Sensitive Species...............................................................................................13

3.10.7 CONSISTENCY WITH THE FOREST PLAN AND OTHER REGULATIONS ................................................................14

3.11 HERITAGE........................................................................................................................................... 1

3.11.1 REGULATORY FRAMEWORK ........................................................................................................................... 1

3.11.2 AREA OF ANALYSIS........................................................................................................................................ 1

3.11.3 EFFECTS ANALYSIS METHODS ....................................................................................................................... 1

3.11.4 EXISTING CONDITION ..................................................................................................................................... 2

3.11.5 ENVIRONMENTAL CONSEQUENCES................................................................................................................. 3

A. Direct and Indirect Effects............................................................................................................................... 3

B. Cumulative Effects........................................................................................................................................... 4

3.11.6 CONSISTENCY WITH THE FOREST PLAN AND OTHER REGULATORY DIRECTION ............................................. 5

3.12 RECREATION, ROADLESS AND WILDERNESS................................................................................ 1

3.12.1 SCOPE OF ANALYSIS & ANALYSIS METHODS................................................................................................... 1

3.12.2 REGULATORY FRAMEWORK............................................................................................................................. 1

A. National Environmental Policy Act ....................................................................................................................1

B. Bitterroot National Forest Plan Direction..........................................................................................................1

C. Recreation Opportunity Spectrum (ROS) ...........................................................................................................2

D. Travel Management Direction............................................................................................................................2

3.12.3 AFFECTED ENVIRONMENT ............................................................................................................................... 3

A. Recreation and Trails..........................................................................................................................................3

B. Wilderness, Inventoried Roadless, and Unroaded Areas....................................................................................4

3.12.4 ENVIRONMENTAL CONSEQUENCES ................................................................................................................12

A. Direct and Indirect Effects.................................................................................................................................12

B. Cumulative Effects............................................................................................................................................19

3.12.5 CONSISTENCY WITH FOREST PLAN, LAWS, AND REGULATIONS .....................................................................20
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Lower West Fork Project Final EIS ii-7

3.13 ECONOMIC ANALYSIS .........................................................................................................................1

3.13.1 SCOPE OF ANALYSIS AND ANALYSIS METHODS ...............................................................................................1

A. Project Feasibility ...........................................................................................................................................2

B. Financial Efficiency.........................................................................................................................................2

C. Economic Impacts (Jobs and Labor Income)..................................................................................................2

D. Environmental Justice.....................................................................................................................................3

3.13.2 REGULATORY FRAMEWORK .............................................................................................................................3

3.13.3 AFFECTED ENVIRONMENT................................................................................................................................3

A. Community Demographics.................................................................................................................................3

B. Bitterroot National Forest Timber Program ......................................................................................................4

C. Bitterroot National Forest Budget Trend ...........................................................................................................5

3.13.4 ENVIRONMENTAL CONSEQUENCES...................................................................................................................5

A. Project Feasibility ..............................................................................................................................................5

B. Financial Efficiency............................................................................................................................................6

C. Design Criteria Activities and Costs..................................................................................................................7

D. Economic Impacts Effects..................................................................................................................................9

3.13.5 ENVIRONMENTAL JUSTICE AND CIVIL RIGHTS .............................................................................................. 10

3.14 VISUAL RESOURCE (Scenery) ...............................................................................................................1

3.14.1 INTRODUCTION ...............................................................................................................................................1

3.14.2 REGULATORY FRAMEWORK............................................................................................................................1

3.14.3 SCOPE OF ANALYSIS AND ANALYSIS METHODS..............................................................................................2

3.14.4 AFFECTED ENVIRONMENT ..............................................................................................................................2

A. Historical and Existing Conditions ....................................................................................................................3

3.14.5 ENVIRONMENTAL EFFECTS .............................................................................................................................6

A. Direct and Indirect Effects..................................................................................................................................6

B. Cumulative Effects..............................................................................................................................................6

3.14.6 CONSISTENCY WITH FOREST PLAN, LAWS, AND REGULATIONS.....................................................7

3.15 HUMAN HEALTH and HERBICIDE USE ...............................................................................................1

3.15. 1 REGULATORY FRAMEWORK ............................................................................................................................1

3.15.2 AFFECTED ENVIRONMENT................................................................................................................................1

A. Method of Analysis.............................................................................................................................................1

3.15.3 ENVIRONMENTAL CONSEQUENCES: DIRECT, INDIRECT, AND CUMULATIVE EFFECTS.......................................2

CHAPTER 4.0

RESPONSE TO COMMENTS

4.1 INTRODUCTION .....................................................................................................................................1

4.2 COMMENTS AND RESPONSES ................................................................................................................1

TABLES

Table 1- 1: Proposed Activities in the Lower West Fork Analysis Area.........................................................2

Table 1- 2: Measurements for Meeting the Lower West Fork Purpose and Need...........................................9
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ii-8 Lower West Fork Project Final EIS 

Table 2-1: Resource Issue Areas Identified During Scoping and Their Use in the Lower West Fork 

Analysis........................................................................................................................................................... 3

Table 2- 2: Unit Treatments Under Alternative 2............................................................................................ 6

Table 2- 3: Mandatory Stewardship Road Treatments Under Alternative 2 .................................................. 8

Table 2- 4: Unit Treatments Under Alternative 3......................................................................................... 13

Table 2- 5: Mandatory Stewardship Road Treatments Under Alternative 3................................................ 14

Table 2- 6: Comparison of Measures to Meet the Purpose and Need of the Lower West Fork Project........ 16

Table 2- 7: Comparison of Activities Connected to Vegetation Treatments for All Alternatives ............... 16

Table 2-8: Mitigation Practices and Design Features in Alternatives 2 and 3 of the Lower West Fork 

Project......................................................................................................................18

Table 2- 9: Adjuvants (Surfactants) Proposed for Use and Allowable Distance to Live Water ................... 25

Table 2- 10: Comparison of Alternative Effects by Issues........................................................................... 26

Table 3.2-1: Vegetation Response Units (VRUs) within the Lower West Fork Analysis Area...................... 6

Table 3.2-2: Historic and Existing Forest Structure Class by Cover Type in Lower West Fork Project 

Area.........................................................................................................................11

Table 3.2-3: Existing Cover Type and Structure Class and Structure Class of Proposed Treatment Units in 

the Lower West Fork Project Area................................................................................................................ 12

Table 3.2-4: Summary of Vegetation Management Effects by Alternative .................................................. 21

Table 3.2-5: Approximate Characteristics of Existing, Post Treatment, and Desired Stand Conditions in 

Unit 70........................................................................................................................................................... 24

Table 3.2-6: Past Harvest Activities -1950s through 2007............................................................................ 33

Table 3.2-7: Past Planting, Natural Regeneration, and Timber Stand Improvement Activities - 1950s 

through 2007.................................................................................................................................................. 35

Table 3.3-1: Vegetation and Fire Descriptors Used in the Lower West Fork Analysis................................. 6

Table 3.3-2: Fire Regime Descriptions for the Lower West Fork Area ......................................................... 7

Table 3.3-3: Area of Existing Fire Types Modeled with a South, Southwest, and West Wind Scenario 

(Results were combined to determine area) .................................................................................................. 12

Table 3.3-4: Fire Type Area by Alternative in the Lower West Fork Project Area, Modeled with Uphill 

Wind Scenario ............................................................................................................................................... 14

Table 3.4-1: National Ambient Air Quality Standards for Particle Pollution Set by the Clean Air Act ........ 4

Table 3.4-2: Maximum Downwind Concentrations of PM2.5 (ug/m3) for Each Modeling Scenario Used in 

the Smoke Impacts Spreadsheet (SIS) and Mitigations and Considerations................................................... 9

Table 3.4-3: Particulate Matter, PM2.5 and PM10 Produced (Tons) in Each Alternative over the Next 15 

Years........................................................................................................................12

Table 3.5-1: Landtype Mapping Units (LMUs) with Potential Limitations for Management Activities. .... 4

Table 3.5-2: Landtype Mapping Units (LMUs) with Compaction Potential.................................................. 5

Table 3.5-3: Commercial Thinning Units with Detrimental Soil Disturbance (DSD). ................................ 5

Table 3.5-4: Rombo Fire Burn Severity Analysis based on Burned Area Reflectance Classification 

(BARC) Data................................................................................................................................................... 7

Table 3.5-5: Coarse Woody Debris (CWD) Requirements for Soil Productivity ........................................ 16

Table 3.5-6: Summary of Ground-based Activities and Potential DSD for each Alternative...................... 18

Table 3.5-7: Summary of Conventional Skyline Yarding and Tracked Line Machine Yarding and Potential 

DSD for each Alternative .............................................................................................................................. 21

Table 3.5-8: Temporary Roads and Potential DSD for each Alternative ..................................................... 24

Table 3.5-9: Herbicide Characteristics in Soils............................................................................................ 25
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Lower West Fork Project Final EIS ii-9

Table 3.5-10: Detrimental Soil Disturbance Calculations for All Proposed Treatment Units (Includes all 

units for both Alternatives 2 &3). ..................................................................................................................33

Table 3.5-11: Cumulative Harvest and Site Preparation Activities in the Project Area ...............................36

Table 3.5-12: Summary of Effects on the Soil Resource..............................................................................43

Table 3.6-1: Impaired Water Body and Probable Cause(s) for Impairment in the Lower West Fork Project 

Area..........................................................................................................................2

Table 3.6-2: Sediment Contributions from the Road System in the Lower West Fork Project.......................9

Table 3.6-3: Existing Condition of HUC 0302, Boulder Creek......................................................................9

Table 3.6-4: Existing Condition of HUC 0303, Piquett Creek .....................................................................10

Table 3.6-5: Existing Condition of HUC 0305, Lower West Fork...............................................................12

Table 3.6-6: Watershed Improvement Cost Estimates on the Lower West Project.......................................19

Table 3.6-7: Proposed Equipment Routes, including temporary roads..........................................................22

Table 3.6-8: Stored or Decommissioned Roads under Alternative 2............................................................23

Table 3.6-9: Priority of Watershed Restoration Projects Not Associated With Timber Harvest in Alternative 

2 of the Lower West Fork Analysis Area.......................................................................................................24

Table 3.6-10: Condition of HUC 0302, Boulder Creek, Following Treatment .............................................26

Table 3.6-11: Condition of HUC 0303, Piquett Creek, Following Treatment...............................................27

Table 3.6-12: Condition of HUC 0305, Lower West Fork, Following Treatment.........................................29

Table 3.6-13: Proposed Equipment Routes, including temporary roads, in Alternative 3............................31

Table 3.6-14: Stored or Decommissioned Roads under Alternative 3...........................................................32

Table 3.6-15: Priority of Watershed Restoration Projects Not Associated With Timber Harvest in 

Alternative 3 of the Lower West Fork Analysis Area....................................................................................33

Table 3.6-16: Condition of HUC 0303, Piquett Creek, Following Treatment...............................................34

Table 3.6-17: Condition of HUC 0305, Lower West Fork, Following Treatment.........................................35

Table 3.7-1: Percent of Fish Habitat Burned and Fire Severity on Fish-Bearing Streams in the Piquett Creek 

Watershed ........................................................................................................................................................5

Table 3.7-2: Annual Mean Maximum Water Temperature( ̊C) in Fish -Bearing Streams of the Lower West 

Fork Analysis Area Between 2000 and 2006.................................................................................................10

Table 3.7-3: Estimate of Log Truck Traffic on Road Segments....................................................................16

Table 3.7-4: Herbicide Use Restrictions in RHCAs ......................................................................................26

Table 3.7-5: Maximum Annual Sprayable Acreage for each Herbicide with No Observable Effect (or

equivalent) to Trout........................................................................................................................................27

Table 3.7-6: Fisheries Sensitive Species Biological Evaluation and Listed Species Biological Assessment -

Summary of Determination of Effects. ..........................................................................................................33

Table 3.8-1: Western Montana Zone Old Growth Type Characteristics (Green et al. 1992, errata 2005) .....3

Table 3.8-2: Percentage of Old Growth Habitat on Suitable Land by Management Area and Drainage .......6

Table 3.8-3: Snags per Acre by Habitat Type as Cited in the Literature ......................................................12

Table 3.8-4: Elk Populations Trends in the Bitterroot Valley and Hunting District (HD) 250. ...................14

Table 3.8-5: Open Road Density and Elk Habitat Effectiveness in the Lower West Fork Analysis Area ...16

Table 3.8-6: Open Route Density in the Lower West Fork Analysis Area...................................................26

Table 3.8-7: EHE Amendments to the Forest Plan since 1987.....................................................................27

Table 3.8-8: Summary of Effects on Elk Habitats........................................................................................28

Table 3.8-9: Area of Lynx Habitat within Treatment Units..........................................................................44

Table 3.9- 1: Biological Agents Used on the Bitterroot National Forest........................................................4

Table 3.9- 2: Noxious Weed and Cheatgrass Locations in Alternatives 2 and 3.............................................7
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ii-10 Lower West Fork Project Final EIS 

Table 3.10-1: Sensitive Plants That May Occur in the Lower West Fork Analysis Area .............................. 2

Table 3.10-2: Sensitive Plants Not Considered in the Lower West Fork Analysis........................................ 5

Table 3.10-3: Sensitive Plants and Sensitive Plant Habitat by Unit............................................................... 8

Table 3.12- 1: Wilderness Attributes and Roadless Characteristics............................................................... 4

Table 3.12- 2: Alternative Comparison of the Proposed Treatments in Unroaded Areas............................. 15

Table 3.13-1: Economic Measures of Success and Analysis Methods ........................................................... 2

Table 3.13-2: The Trend in Volume Cut and Sold for the Bitterroot National Forest and Revenue Received4

Table 3.13-3: Total Bitterroot NF Budget in Nominal and Real Dollars by Year .......................................... 5

Table 3.13-4: Project Feasibility and Financial Efficiency Summary (2008 dollars) ..................................... 6

Table 3.13-5: Activity Expenditures by Alternative over a Five-Year Period (2008 dollars)......................... 8

Table 3.13-6: Optional Resource Activities not Tied to Commercial Harvest, and Their Potential Funding 

Sources ............................................................................................................................................................ 9

Table 3.13-7: Total Employment and Labor Income (2006 dollars) over the Life of the Project................. 10

Table 3.14-1: Scenic Integrity Objectives for Management Areas (USDA Forest Service 1995).................. 1

Table 3.14-2: Percent of Scenic Integrity Objectives by Management Area in the Lower West Fork 

Analysis Area .................................................................................................................................................. 3

Table 3.14-3: Viewpoint Locations For Lower West Fork Project................................................................. 3

Table 3.15-1: Comparison of Potential Herbicides Used in the Lower West Fork Analysis Area ................ 2

FIGURES

Figure 1-1: Vicinity Map of the Lower West for Project Area......................................................3

Figure 1- 2: Management Areas (MAs) in the Lower West Fork Analysis Area.......................................... 11

Figure 2-1: Alternative 2 Treatments on the West Side of West Fork of the Bitterroot River...................... 31

Figure 2-2: Alternative 2 Treatments on the East Side of West Fork of the Bitterroot River....................... 33

Figure 2-3: Alternative 3 Treatments on the West Side of West Fork of the Bitterroot River...................... 35

Figure 2-4: Alternative 3 Treatments on the East Side of West Fork of the Bitterroot River....................... 37

Figure 3.2-1: Vegetation Response Units (VRU) in the Lower West Fork Analysis Area............................. 7

Figure 3.2-2: Forest Size Classes in the Lower West Fork Analysis Area.................................................... 13

Figure 3.2-3: Timber Harvest by Decade in the Lower West Fork Project Area.......................................... 17

Figure 3.2-4: Past Timber Harvest in the Lower West Fork Analysis Area.................................................. 19

Figure 3.2-5: Overlap of Boulder Creek RNA and Old Growth Stand Conditions in Unit 70 of the Lower 

West Fork Project.......................................................................................................................................... 23

Figure 3.3-1: Fire Ignitions and Wildland Fires in the Lower West Fork Analysis Area over the Last 30

Years........................................................................................................................9

Figure 3.3-2: Fires per Year in the Lower West Fork Analysis Area........................................................... 10

Figure 3.3-3: Human and Lightning Caused Fires per Decade in the Lower West Fork Analysis Area ..... 10

Figure 3.3-4: Percent of Total Fires That are Human and Lightning Caused per Decade.....................10

Figure 3.3-5: Potential Fire Types Based on Existing Conditions..................................................13
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Lower West Fork Project Final EIS ii-11

Figure 3.3-6: Acres of Crown Fire by Alternative.........................................................................................15

Figure 3.3-7: Potential Fire Behavior in the Lower West Fork Analysis Area after Treatments under 

Alternative 2...................................................................................................................................................16

Figure 3.3-8: Potential Fire Behavior in the Lower West Fork Analysis Area after Treatments under 

Alternative 3...................................................................................................................................................17

Figure 3.3-9: Fires, Timber Harvest and Fuel Treatments in the Lower West Fork Cumulative Effects 

Analysis Area.................................................................................................................................................19

Figure 3.4-1: Lower West Fork Airshed and Impact Zones ...........................................................................1

Figure 3.4-2: Sula Peak Visibility 18-24 Miles........................................................................7 

Figure 3.4-3: Sula Peak Visibility 186 – 210 Miles.........................................................................................7

Figure 3.4-4: Maximum Annual 24-hour PM2.5 Level from 1994 – 2006 .....................................................7

Figure 3.4-5: 24-Hour Maximum PM2.5 Concentrations Modeled by the Smoke Impact Spreadsheet (SIS) 

Program..........................................................................................................................................................10

Figure 3.4-6: 24-Hour Maximum PM2.5 Concentrations Modeled by the Smoke Impact Spreadsheet (SIS) 

Program..........................................................................................................................................................11

Figure 3.5- 1: Soil Existing Condition Map for the Lower West Fork Analysis Area.. .................................9

Figure 3.5- 2: Cumulative Soil Effects Map for the Lower West Fork Analysis Area.................................41

Figure 3.6-1: Analysis Area and Watershed Boundaries in the Lower West Fork Project..............................3

Figure 3.7-1: Fish Distribution and Abundance in the Lower West Fork Analysis Area...............................3

Figure 3.7-2: Pool Frequency in Fish-Bearing Streams in the Lower West Fork Analysis Area ....................8

Figure 3.7-3: Large Woody Debris Frequency in Fish-Bearing Streams.....................................................9

Figure 3.7-4: Wetted Width-Depth Ratio of Fish-Bearing Streams.................................................................9

Figure 3.7-5: Distribution of Bull Trout and Westslope Cutthroat Trout in the Lower West Fork Analysis 

Area...............................................................................................................................................................22

Figure 3.8-1: Old Growth Habitat in the Lower West Fork Area (2001 to Present).......................................5

Figure 3.8-2: Road Management and Elk Habitat Effectiveness in the Lower West Fork Analysis Area. ..17

Figure 3.8-3: Elk Security Habitat in the Lower West Fork Analysis Area. ................................................19

Figure 3.8-4: Thermal Cover in the Lower West Fork Analysis Area..........................................................22

Figure 3.12-1: Selway-Bitterroot and Allan Mountain Roadless Expanses and Alternative 2 Treatment 

Units in the Lower West Fork Analysis Area ..................................................................................................5

Figure 3.12-2: Proximity of Roads, Past Management, and Alternative 2 Treatments Adjacent to the 

Selway-Bitterroot and Allan Mountain Roadless Expanses in the Lower West Fork Analysis Area............17

Figure 3.13-1: Trend in Volume Sold and Cut on the Bitterroot National Forest (1985, 1995 and 2005).....4

Figure 3.13-2: Trend in Timber Revenue on the Bitterroot National Forest (1985, 1995, and 2005)............5

Figure 3.14-1: Viewpoint #1 – West Fork Lodge on West Fork Road............................................................4

Figure 3.14-2: Viewpoint #2 - From Sam Billing Campground – Boulder Creek RNA .................................5

Figure 3.14-3: Viewpoint #3 - From West Fork Road Looking Towards Triple Creek ..................................5
Table of Contents

ii-12 Lower West Fork Project Final EIS 

APPENDIX

APPENDIX A – Best Management Practices

APPENDIX B – Past, Present and Reasonably Foreseeable Activities

APPENDIX C – Literature Cited

APPENDIX D – Glossary

APPENDIX E – List of Preparers

APPENDIX F – Forest Plan Amendments

APPENDIX G – DEIS Comment Letters
LOWER WEST FORK PROJECT

FINAL ENVIRONMENTAL IMPACT STATEMENT

Bitterroot National Forest

West Fork Ranger District

July 2010

Lead Agency: USDA Forest Service

Responsible Official: Julie K. King 

Forest Supervisor

Bitterroot National Forest

 1801 North 1st Street

Hamilton, MT 59840 

 

For Information Contact: Dave M. Campbell 

West Fork District Ranger 

Bitterroot National Forest 

6735 West Fork Road 

Darby, MT 59829 

(406) 821-3269 

Copies of this Final Environmental Impact Statement are available in compact disc (CD) format at 

the West Fork Ranger District at the address above and can be viewed at the Bitterroot National 

Forest’s web site: http://www.fs.fed.us/rl/bitterroot/projects/

Abstract: This Final Environmental Impact Statement (FEIS) describes the effects of 

implementing three alternatives in the Lower West Fork analysis area on the West Fork Ranger 

District of the Bitterroot National Forest. The analysis area includes the Wildland Urban Interface 

(WUI) along the West Fork of the Bitterroot River (West Fork River). The Bitterroot Community 

Wildfire Protection Plan identified this area as a high treatment priority. Soil, watershed, and 

fisheries management needs were also identified in the analysis area. The four purposes and 

objectives of this project include: 

1. Reduce Fuel Loads and Crown Fire Hazard in Low Elevation Forest 

Reduce the potential for stand-replacing crown fires in and adjacent to the WUI. This will provide 

more fire management options in the event of unplanned ignitions and allow the return of frequent, 

low intensity surface fire to which the low elevation forests are adapted in the Lower West Fork 

analysis area.

2. Improve Forest Resilience to Natural Disturbances, Particularly the Ponderosa Pine 

Component 
In the absence of disturbance, specifically surface fire, the low elevation ponderosa pine forests 

have experienced shifts in composition and structure. Historically, frequent, low intensity surface 

fire maintained ponderosa pine on the drier, low elevation sites by killing the seedlings and 

saplings of more shade tolerant tree species and creating seedbed conditions that favored ponderosa 

pine regeneration. In the absence of fire, the proportion of shade tolerant trees has increased and 

ponderosa pine regeneration has decreased. Thinning in the drier ponderosa pine forests removes 

the shade tolerant understory and increases crown spacing between the larger ponderosa pine in the 

overstory. This treatment will reduce stocking and the potential for crown fire. It will improve the 

health and vigor of the large pines, and their ability to resist insect and disease attacks and survive 

fires. 

3. Maintain or Increase the Shade Intolerant Forest Component, Especially Ponderosa Pine 

The dry, low elevation forest is a well- to over-stocked mixture of ponderosa pine and Douglas-fir 

with increasing levels of Douglas-fir regeneration in the understory. Thinning these forests from 

below would open the canopy and retain the mature ponderosa pine component. These conditions 

would favor ponderosa pine regeneration, which is well-adapted to these sites. Ponderosa pine 

with sufficient growing space is resistant to insects, disease, and fire, and would be resilient to 

environmental changes. 

4. Improve Overall Soil, Watershed, and Fisheries Conditions

Sediment and temperature modification have caused the Montana Department of Environmental 

Quality to list the West Fork River as impaired. This project identified road segments that 

contribute sediment to streams and culverts that block fish passage and isolate populations. The 

Interdisciplinary Team reviewed these roads and culverts and identified the roads no longer needed 

for resource management. Reducing sediment contributions from these roads would improve water 

quality in the West Fork River and bring it closer to being delisted. Removing or replacing 

culverts blocking fish passage would restore genetic exchange between fragmented bull trout and 

westslope cutthroat trout populations. Genetic exchange would improve the genetic diversity of 

the fish stocks and their resilience to changing environmental conditions. 

Three proposed commercial thin units have soil conditions that are near or exceed Region 1 Soil 

Quality Standards. In addition, the analysis area contains approximately 297 acres of terrace 

plantations. The soils on the terrace benches are highly compacted. Subsoiling and/or leaving 

coarse woody debris on these soils would accelerate soil rehabilitation. 

Alternative 2, the Proposed Action, would treat approximately 5,056 acres; Alternative 3 would treat 

approximately 3,599 acres. About 84 percent of the treatments are in the WUI in Alternative 2; about 94 

percent are in the WUI in Alternative 3. Both sides of the West Fork River would be treated using 

commercial thinning and prescribed fire in Alternative 2. In Alternative 3, most of the treatment areas are 

on the west side of the river. The terrace plantations would be treated on both sides of the River in 

Alternative 3, as would the non-commercial thin units. Both alternatives would reduce fuels and thin trees 

to improve stand resiliency to fires, insects, and disease. Both alternatives would generate some revenues 

that could be used for stewardship projects. However, neither alternative would generate enough revenue 

to complete all the resource opportunities identified.

Forest Plan amendments are proposed for Alternative 2 and 3 related to coarse woody debris, thermal 

cover, and elk habitat effectiveness.

Alternatives 2 and 3 are not expected to have significant negative impacts on issues identified through 

scoping. Analysis shows all issues were resolved through project design or the use of common mitigation 

measures. 
Summary

Lower West Fork Project Final EIS Summary i

SUMMARY

INTRODUCTION 

The West Fork Ranger District of the Bitterroot National Forest proposes to reduce fuels and rehabilitate 

soil, watershed, and fisheries conditions within the 38,400 acre Lower West Fork analysis area. Fuels 

would be reduced using commercial and non-commercial thinning, and prescribed fire. Soils would be 

rehabilitated by subsoiling compacted areas and leaving coarse woody debris at levels that would enhance 

the soil building processes. Roads would be stored or decommissioned to reduce the number of sediment 

contribution points, which would also entail removing or replacing culverts. Culvert removal or 

replacement would re-establish connections between stream systems and restore fish passage to isolated 

habitat. 

The Lower West Fork analysis area is located about 15 air miles southwest of Darby, Montana. It is 

located in T2N R21W Sections 27-36, and T1N R20W Sections 6-8, 17-20, 29-32, T1N R21W Sections 1-

30, 34-36, T1N R22W Sections 1, 12-15, 23-26, T1S R21W Sections 1-4, 10-12, 14-16, 21, 22 PMM, 

Ravalli County, Montana. Most of the analysis area is on National Forest System land; there are about 

3,400 acres of private land along the West Fork of the Bitterroot River (West Fork River). The SelwayBitterroot Wilderness borders the analysis area to the west and Shook Mountain and Medicine Point 

lookout mark the border to the east. 

PROPOSED ACTION

The proposed action would treat units in and adjacent to the Wildland-Urban Interface (WUI) with 

prescribed fire, and commercial and non-commercial thins. Following commercial thins, the units would 

be underburned to reduce slash and fuel loads. Some units would be treated with prescribed fire only and 

thinning understory fuels may be needed before ignition. Approximately 5,056 acres would be treated. 

Treatments are designed to achieve project objectives causing minimal environmental impacts

Watershed and fisheries improvement treatments would decommission approximately 10 miles of road and 

place 19 miles in long-term storage. Twenty-two culverts would be replaced or removed, 16 of which 

contribute sediment to streams and seven that impede fish passage. Soil rehabilitation would occur on 297 

acres of terraces and three harvest units that are near or exceed Region 1 standards for detrimentally 

disturbed soils. 

The Proposed Action would require site-specific Forest Plan amendments to the Bitterroot National Forest 

Plan for elk habitat effectiveness, winter range thermal cover, and coarse woody debris in the Lower West 

Fork analysis area. 

PURPOSE AND NEED FOR ACTION

The Purpose and Need for Action for this project is to: 

1. Reduce Fuel Loads and Crown Fire Hazard in Low Elevation Forest 

Reduce the potential for stand-replacing crown fires in and adjacent to the WUI. This will provide 

more fire management options in the event of unplanned ignitions and allow the return of frequent, 

low intensity surface fire to which the low elevation forests are adapted in the Lower West Fork 

analysis area.

2. Improve Forest Resilience to Natural Disturbances, Particularly the Ponderosa Pine Component 

In the absence of disturbance, specifically surface fire, the low elevation ponderosa pine forests 

have experienced shifts in composition and structure. Historically, frequent, low intensity surface 

fire maintained ponderosa pine on the drier, low elevation sites by killing the seedlings and 

saplings of more shade tolerant tree species and creating seedbed conditions that favored ponderosa 

pine regeneration. In the absence of fire, the proportion of shade tolerant trees has increased and 

ponderosa pine regeneration has decreased. Thinning in the drier ponderosa pine forests removes 
Summary

ii Lower West Fork Project Final EIS Summary 

the shade tolerant understory and increases crown spacing between the larger ponderosa pine in the 

overstory. This treatment will reduce stocking and the potential for crown fire. It will improve the 

health and vigor of the large pines, and their ability to resist insect and disease attacks and survive 

fires. 

3. Maintain or Increase the Shade Intolerant Forest Component, Especially Ponderosa Pine 

The dry, low elevation forest is a well- to over-stocked mixture of ponderosa pine and Douglas-fir 

with increasing levels of Douglas-fir regeneration in the understory. Thinning these forests from 

below would open the canopy and retain the mature ponderosa pine component. These conditions 

would favor ponderosa pine regeneration, which is well-adapted to these sites. Ponderosa pine 

with sufficient growing space is resistant to insects, disease, and fire, and would be resilient to 

environmental changes. 

4. Improve Overall Soil, Watershed, and Fisheries Conditions

Sediment and temperature modification have caused the Montana Department of Environmental 

Quality to list the West Fork River as impaired. This project identified road segments that 

contribute sediment to streams and culverts that block fish passage and isolate populations. The 

Interdisciplinary Team reviewed these roads and culverts and identified the roads no longer needed 

for resource management. Reducing sediment contributions from these roads would improve water 

quality in the West Fork River and bring it closer to being delisted. Removing or replacing 

culverts, blocking fish passage would restore genetic exchange between fragmented westslope 

cutthroat trout populations. Genetic exchange would improve the genetic diversity of the fish 

stocks and their resilience to changing environmental conditions. 

Three proposed commercial thin units have soil conditions that are near or exceed Region 1 Soil 

Quality Standards. In addition, the analysis area contains approximately 297 acres of terrace 

plantations. The soils on the terrace benches are highly compacted. Subsoiling and/or leaving 

coarse woody debris on these soils would accelerate soil rehabilitation. 

PUBLIC INVOLVEMENT AND ISSUES

The Lower West Fork Interdisciplinary Team developed the Proposed Action following a public field trip 

to the Frazier Interface Project, within the Lower West Fork analysis area. The purpose of the field trip 

was to critique Frazier Interface Project implementation with a view of applying the effective features over 

a larger area. The proposed action was published in the Ravalli Republic in March of 2007. Public 

comments and preliminary analysis indicated that treating a larger area than initially proposed would better 

achieve the purpose and need. The Notice of Intent was published on December 12, 2007. The Notice of 

Availability of the Draft EIS was published in the Federal Register April 10, 2009. Key issues were 

identified and used to develop Alternative 3. No new issues were identified during the Draft EIS comment 

period. The key issues are described below and responses to comments are presented in Chapter 4. Some 

comments caused us to re-evaluate our analysis and those changes are incorporated in the Final EIS. 

Issues

Some commenter’s question the need for fuel reduction on National Forest. They suggest fuel reduction is 

only effective within a few tens of meters of a home. Some commenter’s are skeptical that thinning stands 

would reduce crown fire potential and believe it would increase the rate of fire spread and thereby increase 

exposure of people, and ecosystem components and processes to fire. Other commenter’s support fuel 

reduction but believe that logging should not be used to reduce them. Still others who support fuel 

reduction believe timber harvest and slash removal should be used but not prescribed fire. 

Key Issue: Fuel Treatments in the WUI. 
Summary

Lower West Fork Project Final EIS Summary iii

Some commenter’s expressed skepticism about the project motives. They suspect a motive to generate 

timber harvest volume more than reduce fuel hazards. They believe logging will disrupt natural forest 

succession and recovery.

Key Issue: Forest Vegetation Management 

Others believe that tree densities should be lower than currently practiced to offset potential site conditions 

created by climate change. They advocate basal areas between 40 and 60 square feet per acre (ft2/ac) on 

the lower elevation, drier sites and 60-80 ft2/ac on the more moist sites. Still others believe logging is the 

preferred way to remove excess biomass and finance the chipping of small diameter wood for use in the 

creation of bio-fuel and other forms of energy. They recognize broadcast burning as unavoidable but 

consider burning piled fuels as unnecessary.

Some commenter’s are concerned about potential logging impacts on soils (erosion, compaction, and 

displacement), watersheds (erosion and sediment) and fish (silt in streams). 

Key Issue: Sediment and Water Quality. 

ALTERNATIVES CONSIDERED IN DETAIL 

Alternative 1 (No Action) 

This alternative represents the existing condition and baseline data against which the other alternatives are 

compared. Under the No Action alternative, current management plans would continue to guide 

management of the analysis area. Work that is ongoing or previously planned within the project area 

would also continue under this alternative. The No Action alternative is required by the National 

Environmental Policy Act (40 CFR 1502.14). 

Under Alternative 1, no treatments are prescribes to reduce fuel loads, change stand structure, or improve 

watershed, fisheries, or soil conditions. Though no management activities are proposed under this 

alternative, environmental conditions would continue to change and evolve. 

Alternative 2 (Proposed Action) 

Alternative 2 would reduce fuels on approximately 4,760 acres using commercial thinning and prescribed 

fire and 296 acres of existing plantations would be non-commercially thinned. All commercial thin units 

(2,493 acres) would be underburned following harvest except the portion of Unit 1 that exceeds R1 soil 

standards. Prescribed fire only would occur on 1,704 acres. Approximately 84% of the treatment areas 

would occur in the WUI. Approximately 2.2 miles of temporary road and 1.7 miles of tracked line machine 

(TLM) trail would be constructed to access timber. Individual lengths of road or trail vary between 100 

and 2,100 feet (Table 2-2). TLM trail requires level pads, 20 by 20 feet at 125-150 foot intervals, on which 

the line machine stands. 

Almost 19 miles of road would be stored and another 10 miles would be decommissioned (Fig. 2-2). 

Twenty-two culverts would be removed at road-stream crossings, 16 of which deliver sediment to streams 

and two that block fish passage. Storing or decommissioning 11.6 miles of road would be mandatory 

mitigation to off-set short-term timber sale effects. This mitigation would remove 15 culverts, 11 of which 

contribute sediment to streams. The remaining roads that are not mitigation would be decommissioned or 

stored as funding is available. 

Soil rehabilitation would occur in proposed commercial thinning units (1, 3, and 12) to improve soil quality 

in areas with historic soil compaction as directed by the Region 1 Soil Quality Standards. Also, soil 

restoration would occur on about 297 acres of terrace plantations after the units are thinned. 

No more than 300 acres would be treated with herbicide annually for about ten years. Areas most be 

treated include roads proposed for decommissioning or storage, haul routes, temporary roads, TLM paths, 

and landings. Skid trails and openings created by the treatments within units may also be sprayed if posttreatment monitoring indicates weeds are encroaching. Approximately 1,400 acres located throughout the 
Summary

iv Lower West Fork Project Final EIS Summary 

project area may require treatment over the ten year period. About 200 of those acres occur along roads, 

landings or TLM paths. 

Alternative 3 

Alternative 3 was developed to respond to three categories of issues: Soil, sediment, and water quality; 

WUI treatments; and forest treatments to restore or maintain resilience. Commercial thinning and 

prescribed fire would not occur on the east side of the West Fork River under Alternative 3 because the 

fires in 2000 and the 2007 Rombo fire have reduced cover and fuel loads over a large area. Noncommercial thinning and terrace unit treatments were retained because their purposes are not to reduce fuel 

loads but to enhance stand development and reduce compaction, respectively. 

Under Alternative 3, fuels would be reduced on approximately 3,302 acres using commercial thinning and 

prescribed fire. Treatments on the west side of the West Fork River would be largely the same as in 

Alternative 2, except the part of Unit 1 with detrimental soil disturbance would not be commercially 

thinned. About 2,091 acres would be commercially thinned and fuels would be reduced on another 1,139 

acres using prescribed fire only. Approximately 91% of the treatment areas would occur in the WUI. 

About 18 miles of road would be stored and 27 miles decommissioned for watershed and fisheries 

improvement. Thirty-three culverts would be removed from road-stream crossings, 23 of which contribute 

sediment to streams. Storing or decommissioning 11.8 miles of road would be mandatory mitigation to offset potential short-term timber sale effects. This mitigation would remove 18 culverts, 12 of which 

contribute sediment to streams. The remaining roads would be decommissioned or stored as funding 

becomes available. 

The interdisciplinary team (ID Team) modified the prescription for the 65-acre portion of unit 1 with 

detrimental soil disturbance to an adaptive management protocol that would reduce ladder fuels, provide 

coarse woody debris, and increase crown spacing. The area would be initially thinned from below and the 

slash would be lopped and scattered to prevent beetle infestation. The slash would be left on the ground at 

least one year so nutrients would leach into the soil. The slash would be burned and the area would be resurveyed to assess residual coarse woody debris on the site. The coarse woody debris goal is 15-20 tons 

per acre. If monitoring indicates residual coarse woody debris is below the required level, larger trees 

would be felled and left on site. Thinning the larger trees would emphasize felling Douglas-fir and 

retaining ponderosa pine. Douglas-fir logs greater than 17 inches diameter and longer than six feet are 

preferred as coarse woody debris because Douglas-fir decays at a slower rate than ponderosa pine and 

would stay on the soil surface longer. This thinning would increase crown spacing and the larger diameter 

components of coarse woody debris. Limbs and treetops would be piled and burned if monitoring indicates 

the fine fuel load increases the potential for high fire intensity. 

SUMMARY OF EFFECTS

Chapter 3 describes the physical, biological, and social or economic resource conditions in the analysis area 

and the anticipated effects on those resources from implementing the alternatives. Effects are analyzed in 

terms of their direct, indirect, and cumulative effects. The following is a summary of the potential effects 

by resource.

Vegetation

Forest would benefit from the implementation of Alternative 2. More area would be treated so forest 

composition and structure would change over a larger area. More forest would retain large, fire-resistant 

trees with better crown spacing and lower stocking. These forests would be more resilient to disease and 

insect attacks and fires would tend to be of lower intensity. The more open understory and improved fire 

resistance of the forest would facilitate the use of low intensity fire, both natural and prescribed, to maintain 

the mature overstory and perpetuate the regeneration of ponderosa pine. 
Summary

Lower West Fork Project Final EIS Summary v

Alternative 3 would create similar conditions on the west side of the West Fork River but would not treat 

enough area on the east side to influence fire behavior. The fires of 2000 and the Rombo fire have burned 

on the periphery of this area but internal forest conditions remain overstocked with less fire-resistant tree 

species and high fuel loads. In addition, these units would be susceptible to bark beetle attacks because of 

their high stocking. Bark beetle populations are not currently high in the analysis area but they are 

increasing in adjacent areas.

Alternative 1 would not change forest conditions and there is strong potential that experiences of the fires 

in 2000 or the Rombo fire would be repeated. They would also be susceptible to bark beetle outbreaks 

because continuity of the high stocking of the forest. 

Fire and Fuels

Fuel reduction treatments would decrease fire behavior by reducing fuel loads and increasing the space 

between tree crowns. Rates of surface fire spread may increase with treatment because the forest floor is 

more exposed to solar heating, wind passes more easily through the stand, and fine, herbaceous fuels 

proliferate with more direct sunlight. However, the absence of ladder fuels prevents surface fires from 

being drawn into the tree crowns, which reduces the fire severity and fire type. Decreases in fire type 

categories are due to a reduction of surface, ladder, and canopy fuels. Additional reduction in fire type is 

expected outside of treatment areas because fires would be forced to either move through treatment zones 

as slower moving fires, or flank around treatment areas.

The No-Action alternative does not change the potential fire types in the analysis area. As forest structure 

becomes more homogeneous and fuel loads continue to increase, more land area would transition from 

surface to crown fire type. Fire management responses would continue to emphasize aggressive 

suppression to prevent fires moving onto private lands and to prevent the loss of large ponderosa pine trees 

that are susceptible to mortality due to ladder fuel development. 

Each of action alternatives reduces the area of potential crown fire behavior under extreme fire danger 

(overall reduced fire type). Alternative 2 has the largest reduction in fire behavior with a decrease of 1,330 

acres of potential crown fire. Alternative 3 reduces the area of potential crown fire by 886 acres. 

Alternative 2 shows a greater decrease in the area of potential crown fire because more area is treated than 

under Alternative 3. Under Alternative 3 the majority of the Wildland Urban Interface on the east side of 

the West Fork River would still exhibit crown fire behavior. 

Alternative 2 & 3 would allow more fire management options to be available besides aggressive fire 

suppression when responding to fire starts in the area. The decision space for managing fires would 

increase because the reduced fuel loads and ladder fuels, and the juxtaposition of treatment areas would 

reduce the potential fire behavior from crown fire to mostly surface fire. In addition to the reduction in fire 

behavior in the treated areas, there would be greater opportunity to use wildland fire in the adjacent 

wilderness and roadless areas because the fire would be easier to manage and control when it reaches the 

treated areas. This would allow fire to play a more natural role in resource management while balancing 

the risks to adjacent private lands and maintaining the visual quality people value. It would result in long 

term benefits to the ecosystem and increase the options of using prescribed fire to maintain the fire adapted 

ecosystems in the future. 

Air Quality

All alternatives have the potential to produce smoke from wildland fires. Wildland fires will continue to 

burn and produce smoke, primarily during the summer months. The estimated emissions of the action 

alternatives are nearly two to six times below wildland fire emissions. The modeling shows 24-hour 

maximum PM2.5 concentrations emitted from proposed prescribed fire activity would be below the 35

μg/m3 threshold within 0.1 mile downwind of the burn and concentrations drop off rapidly after 0.1 mile 

and never exceed the threshold. Daily particulate matter standards would be met in Alternatives 2 and 3 by 
Summary

vi Lower West Fork Project Final EIS Summary 

following the Montana/Idaho Smoke Management Plan. Smoke from prescribed burning may cause shortterm impacts on recreation and transportation in and near the project area. The size and location of a 

prescribed burn and weather conditions (e.g. temperature, wind, atmospheric stability and mixing, and fuel 

moisture) determine how much and in what direction smoke travels. Residents in or near the mouths of 

drainages might experience short-term periods of smoke during early morning inversions. 

No smoke would be produced by management ignitions under Alternative 1, the No Action alternative. 

However, Alternative 1 would not reduce current heavy fuel loadings and fuel continuity on the Lower 

West Fork project area. For this reason, it is the least effective of the three alternatives in reducing 

potential smoke emissions and associated pollutants from future wildland fires. In the absence of fuel 

reduction, and in the event of future wildland fire, varying levels of smoke could persist in the Bitterroot 

Valley for several weeks. Health and visibility could be adversely affected depending on local climatic 

conditions, level of smoke dispersion, and amount of smoke the fire produces. 

Alternative 2 would most effectively reduce potential smoke emissions and associated pollutants from 

large, uncontrolled wildland fires in the long term because fuels would be treated over more area. 

Although this alternative would produce the highest smoke emissions over the next 15 years, those 

emissions would take place with approval of the Airshed Group, which would reduce impacts to people and 

communities as compared to uncontrolled wildfires. Alternative 3 has the lowest smoke emissions of the 

action alternatives over the next 15 years because less area would be treated. With less area treated under 

Alternative 3, the potential for higher smoke emissions and associated pollutants from large, uncontrolled 

wildland fires increases.

Soils

Soil resources would be the least impacted and benefit the most from Alternative 3. Alternative 3 has 794 

fewer acres of commercial thinning than Alternative 2 – 742 acres of ground-based yarding and 958 acres 

of skyline yarding. Commercial thin operations have the potential to detrimentally disturb soils on about 

151 acres. Overall, less area of commercial thinning in Alternative 3 would cause less soil disturbance, 

particularly from ground-based operations. Soils are the most heavily disturbed in Unit 1. Treatments in 

Unit 1 would not involve commercial harvest in Alternative 3. Treatments would include slashing and 

under burning to achieve fuel reduction objectives. Additional trees (8 inch dbh and greater) may be felled 

to meet 15 to 20 tons per acre of coarse woody debris needed for soil rehabilitation and to create adequate 

tree spacing to meet silvicultural objectives. In Alternative 3, soils will be treated on 297 acres of terraced 

plantations and soil compaction would be actively decompacted in Units 3 and 12. 

Alternative 2 has the most commercial thinning – 1,044 acres of ground-based yarding and 1,450 acres of 

skyline yarding. Commercial thin operations have the potential to detrimentally disturb soils on about 220 

acres. In Alternative 2, commercial harvest would be utilized to treat fuels in Unit 1. The commercial 

harvest would occur during winter conditions to protect soils and minimize additional compaction. Coarse 

woody debris would be left in Unit 1 at 15 to 20 tons per acre to improve future soil conditions. Similar to 

Alternative 3, soil rehabilitation treatments will be completed on 297 acres of terraced plantations and soil 

compaction would be actively decompacted in Units 3 and 12. 

No commercial thinning or active soil rehabilitation would occur under Alternative 1. Soils that currently 

exceed Region 1 Soil Quality Standards will continue to recover naturally. Time periods greater than 50 

years may be required to improve soil structure on soils compacted by past harvest operations. Regression 

data by Froehlich (1985) indicates that 40 to 50 years are expected to naturally reduce bulk density levels to 

baseline conditions in sandy loam soils like those in the project area.

Watershed

The watershed resource would benefit from the implementation of Alternative 2. Sixteen known sediment 

producing culverts would be removed and the work site restored (seeding, fertilizing, mulching, shrub 
Summary

Lower West Fork Project Final EIS Summary vii

planting). This activity would reduce or eliminate sediment contribution to area tributaries and ultimately 

the West Fork River. Another six culverts that do not contribute sediment would also be removed as part 

of road storage or decommissioning. In the long-term, the reduction of sediment in this alternative would 

contribute to the eventual delisting of the West Fork River as a sediment impaired stream.

The vegetation management included in Alternative 2 carries some risk of increased erosion and sediment 

contribution from the prescribed fire activities and log haul on roads near streams. The mandatory 

mitigation in Alternative 2 would off-set the higher potential sediment associated with vegetation 

management. Other mitigation, specifically straw bale sediment filters and traps, would reduce the risk of 

sediment contributions associated with log hauling. 

Alternative 3 would benefit the watershed resource more than Alternative 2 by reducing the amount of 

prescribed fire that would occur in the Piquett watershed, thus reducing potential sediment contributions 

from that activity. There would more road storage and decommissioning, which would remove 23 culverts 

at known sediment contributing sites. Vegetation would be restored at each site to reduce erosion. Another 

10 culverts would be removed during road storage and decommissioning. Straw bale filter/sediment traps 

would be included where needed with this alternative to reduce the risk of sediment contributions 

associated with log hauling.

Under Alternative 1, there would be no change in road conditions. Current trends in sediment contributions 

would continue and the West Fork River would not move towards the sediment reduction target identified 

in the Bitterroot Headwaters Restoration Plan. 

Fisheries

Alternative 1 is likely to have a neutral effect on the fishery and result in a continuation of the existing 

condition. Although both Alternatives 2 and 3 are expected to maintain the quality of the fishery at or near 

its existing condition in the short-term, Alternative 3 is the more favorable of the two action alternatives 

because there would be much less log haul traffic in the Piquett Creek drainage with a lower risk of 

sediment entering bull trout and westslope cutthroat trout habitat from haul roads. In the long-term, 

Alternative 3 would be the most favorable action alternative because it would result in better watershed 

health and less road sediment inputs than Alternative 2. Alternatives 2 and 3 would both eliminate seven 

fish culvert barriers and improve fish population connectivity to the same degree. 

Wildlife

There are no threatened and endangered wildlife species known to occupy the Lower West Fork analysis 

area. 

Wildlife would benefit from the implementation of Alternative 2. More old growth areas would be treated, 

which would reduce the potential of losing the stand in a fire. Alternative 2 would also benefit old growth 

‘associate’ species by treating more marten, fisher, pileated woodpecker, and flammulated owl potential 

and suitable habitat. While there is potential to lose some fisher habitat, implementation would not affect 

the overall population or species viability. Elk habitat effectiveness would improve from current conditions 

in all 3rd order drainages, however only one of these drainages would improve enough to meet Forest Plan 

standards. Five 3rd order drainages would meet Forest Plan standards. There would be minimal to no 

impacts on other sensitive species. Overall, this alternative benefits wildlife by reducing the risk of losing 

existing old growth habitat to fire or insect outbreaks by reducing stand density, ladder fuels, and fuel 

loads. 

Under Alternative 3, old growth and wildlife conditions would be similar to those under Alternative 2 on 

the west side of the West Fork River. However, less area would be treated on the east side of the river. 

Similar conditions for old growth ‘associate’ species would exist except on a smaller scale. Elk habitat 

effectiveness would again improve from current conditions in all 3rd order drainages so five drainages

would meet Forest Plan standards. There would be minimal to no impacts on other sensitive species.
Summary

viii Lower West Fork Project Final EIS Summary 

Alternative 1 would not immediately change the existing habitat quality or habitat conditions in old growth 

stands for old growth ‘associate’ species. There is a greater risk of losing habitat as increasing stand 

densities and fuel loads amplify the probability of large, stand replacement fires. Marten, pileated 

woodpecker, and fisher habitat quality would likely continue to improve in the short-term while 

flammulated owl habitat would continue to decline. Overall, the potential for a large fire to create 

unsuitable habitat for any of the old growth ‘associate’ species would increase. Elk habitat effectiveness 

would not meet Forest Plan standards in six of the ten 3rd order drainages. There would be minimal to no 

impacts on other sensitive species.

Noxious Weeds

Alternative 1 would have no direct change on the spread of weeds. The current trend of noxious weeds 

colonizing openings created by natural events or other activities would continue. Following a severe fire, it 

is highly likely that the vigor and spread of noxious weeds would increase.

Under Alternative 2, ground disturbance from timber harvest and prescribed fire may increase the spread of 

noxious weeds. However, mitigation measures would limit the risk of spread into areas that currently do 

not have weeds or additional spread in areas that do have weeds. The risk of weed spread in Alternative 2 

is greater than in Alternative 3 because there would be more area of ground disturbance from yarding and 

prescribed fire. 

The spread of noxious weeds is possible under Alternative 3, though the risk of spread is less than in 

Alternative 2. However, mitigation measures would limit the risk of spread into areas that currently do not 

have weeds and additional spread in areas that do have weeds, though not to the extent of Alternative 2. 

The option to spray new weed infestations would not be available under this alternative so weeds may 

spread faster though in less area than in Alternative 2. In the event of a severe fire, there is higher risk of 

noxious weeds spreading into areas where thinning and prescribed fire do not occur. 

Threatened, Endangered, and Sensitive Plant Species

Alternative 1 would have no direct impact on individual sensitive plants, habitat, species viability, or 

geographic distribution. The current trend of forest encroachment on dwarf onion, Lemhi penstemon, and 

Rocky Mountain paintbrush populations will continue and competition with noxious weeds will continue at 

the current rate. There is higher likelihood of individual sensitive plant loss from heating of below ground 

plant tissue and higher potential for noxious weed competition in the event of a severe fire.

Mitigation measures in Alternative 2 would prevent adverse effects on sensitive plant population viability 

or geographic distribution. There may be some adverse effects on individual plants and potential habitat 

from ground disturbance, prescribed fire, and potential weed spread. The extent of potential impacts in 

Alternative 2 would be greater than Alternative 3.

Effects to all known populations of sensitive plants will be mitigated under Alternative 3. There may be 

some adverse effects to individual plants and potential habitat from ground disturbance, prescribed fire, and 

potential weed spread. The extent of potential impacts in Alternative 3 would be less than in Alternative 2. 

However, there is a higher risk of a severe fire in the untreated areas. in the event of a severe fire, the 

potential loss of individual sensitive plants would be higher because of heating below-ground plant tissue 

and increased noxious weed competition in areas where thinning and prescribed fire do not occur. 

Heritage

No cultural sites or traditional cultural properties are located within or in close proximity to any of the 

proposed treatment units. Project activities would have no effects on known cultural resources. 
Summary

Lower West Fork Project Final EIS Summary ix

Recreation, Roadless, and Wilderness

No effects or changes to recreation opportunities would occur under any of the alternatives because the 

project would not interfere with access to trailheads or authorized special use areas. 

No effects or changes to inventoried roadless areas would be expected under any of the alternatives because 

no treatment units occur in the inventoried roadless areas. Some prescribed fire, commercial thin, and 

temporary road construction would occur in the unroaded areas under both Alternatives 2 and 3. These 

activities and facilities would temporarily compromise the natural integrity, apparent naturalness, and 

perception of remoteness and solitude. No special features in the unroaded areas would be negatively 

affected by the proposed activities. The effects would be the same under Alternatives 2 and 3. On the west 

side of the West Fork River, treatments are essentially the same under the action alternatives. On the east 

side of the West Fork River, parts of two prescribed fire units and one commercial thin unit occur in the 

unroaded areas in Alternative 2. The treatments would not adversely affect the unroaded characteristics 

because these areas have little value as roadless areas in and of themselves or as adjacent to the inventoried 

roadless area. Under Alternative 3, none of the treatments would occur in the unroaded areas. 

There would be no direct effects on the Selway-Bitterroot Wilderness because no activities are proposed in 

the Wilderness. The distance and direction of the proposed activities from the Wilderness and intervening 

landforms would mitigate any indirect effects of the proposed activities on Wilderness values.

Economics

Project Feasibility

The estimation of project feasibility was based on the Region 1 transaction evidence appraisal model. The 

sawlog estimated high bid for alternatives 2 and 3, $15.37/CCF and $13.37/CCF, respectively, was 

compared to base rates ($1.0/CCF). Base rates are revenues considered essential to cover regeneration plus 

minimum return to the federal treasury. The estimated high bids for Alternatives 2 and 3 indicate that each 

of the alternatives is feasible (highly likely to sell). The revenue estimates from the feasibility analysis are 

used in the financial efficiency analysis. 

Financial efficiency is one tool used to make the decision. Many things cannot be quantified, such as 

increases in the fire management options available to the line officer following treatment, effects on 

wildlife, social impacts to local communities, and restoration of watersheds and vegetation. The decision 

maker takes many factors into account in making the decision.

Financial Efficiency

This analysis is not intended to be a comprehensive benefit-cost or present net value (PNV) analysis that 

incorporates a monetary expression of all known market and non-market benefits and costs. This type of 

PNV analysis is generally used when economic efficiency is the sole or primary criterion upon which a 

decision is made. Many of the values associated with natural resource management are qualitative and are 

not assigned a monetary value. These qualitative values are factors in the decision and are discussed by 

resource area in this document.

The PNV was calculated using Quicksilver, an economic analysis program based on long-term, actual 

resource management projects. A 4% real discount rate was used over the five-year project lifespan (2010-

2014) (PF-ECON-003). Not all project costs are related to the timber sale so two PNVs were calculated. 

One PNV indicates the financial efficiency of the timber sale, including all costs and revenues associated 

with the timber harvest and required design criteria. A second PNV includes all costs for each alternative, 

including optional stewardship activities not related to timber harvest. Sale preparation and sale 

administration costs are approximately $420,750 for Alternative 2 and $286,110 for Alternative 3. 

The timber sale and design criteria in both action alternatives are financially inefficient and more 

financially inefficient when combined with the optional stewardship activities. The No Action Alternative 

has no costs or revenue associated with it and in this case has the highest PNV ($0). Of the action 
Summary

x Lower West Fork Project Final EIS Summary 

alternatives, Alternative 3 has a slightly less negative timber sale PNV at negative $726,549 compared to 

negative $933,864 for Alternative 2. When all of the design criteria and optional stewardship activities are 

included, the Alternative 3 has a negative PNV of $1,646,559 and Alternative 2 has a negative PNV of 

$1,966,013. 

The sale of timber in this project is the result of commercial and non-commercial thinning to meet a variety 

of objectives such as hazardous fuels reduction, forest resilience to natural disturbance, watershed 

improvement, and wildlife habitat improvement. Therefore, in addition to the revenues generated from the 

sale of associated timber, other sources of revenue or appropriated funds must be used to cover the costs 

associated with the optional activities. For activities tied to hazardous fuels reduction, funding from the 

American Recovery and Reinvestment Act may also be available. The costs associated with these optional 

activities range from about $949,147 for Alternatives 3 up to $1.08 million for Alternative 2. When these 

are added to the amounts needed to supplement timber revenue for design criteria the result is that unless 

markets improve and/or bids are higher than base rates, it would require roughly $1.657 and $1.442 million 

in appropriated or partner funding to complete all of the proposed activities in Alternatives 2 and 3, 

respectively. 

Timber products harvested from the proposed project and the non-timber activities would have direct and 

indirect effects on local jobs and labor income. In order to estimate jobs and labor income associated with 

timber harvest, the ID Team assumed that 72 percent of sawlog material would be processed by the sawmill 

and planing sector for Alternatives 2 and 3. The remaining volume would be processed as pulp and paper. 

The ID Team developed expenditures for stewardship activities to estimate jobs and labor income 

associated with them for each alternative. It is important to note that these are not new jobs or income, but 

rather jobs and income that can be attributed to this project.

Economic Effects

Alternative 1 maintains no jobs nor income because there are no activities associated with this alternative. 

Mandatory activities in Alternative 2 would contribute roughly 76 direct and 151 total part and full-time 

jobs, with $2.6 million in direct, and $4.9 million in total labor income, spread across the five-year life of 

the project. The ID Team also expects that completing all the optional stewardship activities 

(noncommercial thinning and additional road decommissioning or storage) would contribute an additional 

14 direct and 19 total part and full-time jobs during a period lasting a little longer than five years. An 

additional $620,000 direct labor income and $781,000 total labor income would be contributed to the 

economic impact area during this period. The mandatory work in Alternative 3, would contribute roughly 

53 direct and 105 total part and full-time jobs with $1.8 million in direct, and $3.4 million in total labor 

income, spread over the five-year life of the project. The Forest Service would expect another 11 direct 

and 16 total part and full-time jobs during this period to complete all the optional stewardship activities in

this alternative. An additional $495,000 direct and $630,000 total labor income would be expected 

compared with just the mandatory work proposed in Alternative 3 over a period lasting five years.

None of the alternatives restrict or alter opportunities for subsistence hunting and fishing by Native 

American tribes. Tribes holding treaty rights for hunting and fishing on the Bitterroot National Forest are 

included on the project mailing list and have the opportunity to provide comments on this project. 

Environmental Justice and Civil Rights

Alternative 2 and 3 would create more employment and income opportunities than Alternative 1. 

Alternative 2 would have a slightly higher level of opportunity than Alternative 3. Implementation of 

either action alternative would not likely adversely affect minority or low-income populations. 

Visual Resources 

Visual quality objectives would be met under all alternatives. 
Summary

Lower West Fork Project Final EIS Summary xi

Human Health and Herbicide Use

Effects of herbicide use on the general public and applicators would generally be low, a Hazard Quotient 

less than 1 (FEIS 3.15). Mitigation measures, spill prevention, applicator training, low application rates, 

the small, specific areas of application, and posting areas where herbicides are applied would keep direct 

and indirect human exposures low. 

PREFERRED ALTERNATIVE

There are advantages to implementing both Alternative 2 and Alternative 3 and the agency preferred 

alternative is a combination of them. Activities proposed in Alternative 3 would be selected with the 

following additions: Unit 60 on the west side of the river would be commercial thinned, herbicide use as 

described in Alternative 2 would be retained as an option for treating potential noxious weed spread, and 

prescribed fire units on the east side of the river would under burned. 

Unit 60 was not analyzed for treatment under Alternative 3 because the purpose of the alternative was to 

reduce fuels in the WUI on the west side of the river. Unit 60 abuts the Trapper-Bunkhouse analysis area 

and the unit adjacent to it is scheduled for a commercial thin treatment. There are no detrimental effects 

associated with treating Unit 60 and not treating it would diminish the landscape benefits of treatment in 

both project areas. 

To display the difference between vegetation treatments with and without herbicide use, using herbicides to 

control the spread of invasive species was analyzed under Alternative 2 and not analyzed under Alternative 

3. The same parameters for herbicide use as described in Alternative 2 would be applied to Alternative 3. 

Since less vegetation area is proposed for vegetation treatments under Alternative 3, the potential use of 

herbicides would be less. 

Though the headwaters of Piquett Creek and East Piquett Creek have been burned in the past 10 years, 

crown fire potential remains high in the WUI on the east side of West Fork River. Prescribed fire in Units 

64, 65, 69, 71, 72, and 73 would reduce fuels adjacent to private land and provide options in managing 

fires. 

The effects of these additions were analyzed under Alternative 2 and would not exceed the degree of effects 

analyzed in that Alternative.

Summary of Changes

Lower West Fork Project Final EIS Summary of Changes i

SUMMARY OF CHANGES

BETWEEN THE DRAFT AND FINAL EIS

The ID Team made the following major changes in the Final EIS based on public comments received on 

the Draft EIS (DEIS) and from additional field review and analysis. Throughout the document, edits were 

made to more accurately reflect and clarify the purpose and need, issues, alternatives, and effects. 

CHAPTER 1

A legal description of the analysis area was added.

The Forest Plan amendment for snags was removed. Since this is not a salvage or sanitation project, snags 

would not be harvested. There is potential that some snags would need to be felled if they present hazards 

to timber operations as defined by the Occupational Safety and Health Administration (OSHA 29CFR 

110.266(h)(1)(v, vii). However, this would amount to an incidental loss of snags and most, if not all, snags 

would be retained after harvest (FEIS 2-23).

They Wildlife Biologist re-wrote the Forest Plan amendment for winter range thermal cover to read: 

“Thermal cover on winter range will be treated in the Lower West Fork analysis area to the extent needed 

to protect the overstory from loss due to fire.” (FEIS pg. 1-11) The intent is to clarify that thermal cover 

would be modified the least amount possible to achieve the objective of reducing fire intensity and 

maintaining the forest. 

CHAPTER 2

Restored non-commercial thinning of plantations on the east side of the West Fork River. These units were 

added into Alternative 3 because their treatment supports investments made when the stands were 

established and these small areas do not influence fire behavior. The purpose of non-commercial thins in 

the plantations is enhance stand development. There would be no benefit to delaying treatment and there 

are no environmental effects associated with the treatment (FEIS 2-13). 

Clarified which soils, watershed, and fisheries projects would be funded by the timber sale and which 

would be accomplished through other funds (FEIS pg. 2-8, 2-12). 

The ID Team modified Alternative 3 to include an alternate treatment of the portion of Unit 1 with 

detrimental soil disturbance to address the concern that tractor-based yarding equipment would intensify 

soil compaction (FEIS pg. 2-13). They also corrected the area of Unit 1 with detrimental soil disturbance 

to 65 acres.

The ID Team analyzed another alternative, though not in detail, that considered reducing fuels without the 

use of prescribed fire or pile burning (FEIS pg.2-17). This alternative was not analyzed in detail because it 

became readily apparent that it would not achieve the purpose of reducing fuel loads and crown fire 

potential. It does not appear to be technologically or economically feasible at this time to treat all the 

required biomass by only using mechanical methods. 

Enlarged the alternative maps so that each alternative is displayed on two maps. Figures 2-1 and 2-2 

display the treatments and road systems on west and east sides of the West Fork River, respectively. 

Likewise, Figures 2-3 and 2-4 display the treatments and road system for Alternative 3.

CHAPTER 3

The ID Team developed and adaptive management protocol for the portion of Unit 1 with detrimental soil 

disturbance under Alternative 3. This alternate treatment would initiate soil rehabilitation by providing 

coarse woody debris, and to reduce the potential of high intensity fires by reducing ladder fuels and 
Summary of Changes

ii Lower West Fork Project Final EIS Summary of Changes 

increasing crown spacing (FEIS pg. 3.5-17, 3.5-26, 3.5-27). The treatment would be done with hand crews 

and heavy equipment would not be required on the site. 

The ID Team added two maps, Figure 3.5-1 and 3.5-2, to the soils section to display existing conditions 

and cumulative effects. Both maps display proposed treatment units, roads, detrimental soil disturbance,

fire intensities for the 2000 fires and the Rombo fire. The cumulative effects map also displays watersheds

above and below the 20% ECA threshold. The maps help the reader visualize the juxtaposition of the 

various activities and events in the Lower West Fork analysis area and visualize changes following 

treatments (FEIS pg. 3.5-8 and 3.5-31).

Additional logging systems analysis completed since the DEIS provided information on the feasibility of 

implementing ground-based treatments on terrace units. The majority of terrace units will require skyline 

or trackline machine yarding. Units with slopes greater than 40 percent are not suited for ground-based 

operation which limits the ability to complete active decompaction treatments on the terrace benches. As 

an alternative treatment, the skyline yarding operations will be required to leave 10 to 15 tons/acre of 

woody debris specifically on the terrace benches for soil rehabilitation (FEIS pg 3.5-19). 

The ID Team corrected Tables 3.6-4, 3.6-10, 3.6-14 to include the effects of the Rombo Fire on Equivalent 

Clearcut Area and modified our interpretations of the analysis (FEIS pg. 3.6-10, 3.6-11, 3.6-26, 3.6-27, 3.6-

32, 3.6-33, 3.6-37). 

The ID Team re-evaluated elk habitat effectiveness and clarified the analysis methods and parameters 

(FEIS 3.8-15, 3.8-16, 3.8-23, 3.8-24). They added a map, Figure 3.8-2, that displays the open roads and 

routes by 3rd order drainage, trailheads, proposed road treatments in each alternative, and possible closures 

(FEIS pg. 3.8-7). They also included a map of the elk security area, Figure 3.8-3, to show how additional 

road closures would not expand or create additional security area (FEIS pg. 3.8-19).

The ID Team clarified the winter thermal cover existing status (FEIS pg. 3.8-14, 3.8-15) and analysis (FEIS 

pg. 3.8-21, 3.8-24, 3.8-25). They added a map, 3.8-4, to display the current winter thermal cover areas, and 

their juxtaposition with winter range, Management Area 2 winter range, and the proposed treatment areas 

(FEIS pg. 3.8-22). 

In section 3.12, the ID Team refined the analysis of unroaded areas to provide a more site-specific

description of treatment locations and assessment of effects on the unroaded parcels. The ID Team refined 

the map to display the unroaded parcels relative to the proposed treatment areas and provide reference to 

the analysis. They added another map to display the road system, and past treatment areas relative to the 

unroaded parcels and associated inventoried roadless areas. 

The economic analysis was updated in section 3.13 to incorporate changes to the alternatives from additional 

field verification or errors in the draft EIS analysis. Expected revenue was adjusted by updating appraisals 

with the most recent information. Volume separated into sawlog and non-sawlog material, now includes a 

small product adjustment for non-sawlog material, which was applied to the predicted high bid for sawlog 

material. There were also updates made to the project costs associated with design modifications. 

CHAPTER 4

This chapter is the Response to Comments on the DEIS. It contains responses to the comments and copies 

of each letter or e-mail received by the May 26, 2009 deadline.

APPENDIX A

Editorial and format changes were made.

APPENDIX B

No changes were made.
Summary of Changes

Lower West Fork Project Final EIS Summary of Changes iii

APPENDIX C

Added more citations.

APPENDIX D

Added more acronyms.

APPENDIX E

The biography of the new wildlife biologist was added for her assistance with review and organization.

APPENDIX F

A Forest Plan amendment for snags is not needed so the snag analysis was removed. 

Purpose and Need

Lower West Fork Project Final EIS 1-1

CHAPTER 1.0

PURPOSE AND NEED

1.1 INTRODUCTION 

The Lower West Fork project is located in Ravalli County, approximately 15 miles southwest of Darby, 

Montana. The analysis area includes 38,400 acres between the Selway-Bitterroot Wilderness to the west 

and Shook Mountain and Medicine Point lookout to the east. Pierce Creek drainage borders the analysis 

area on the north, and Wheeler Creek and Piquett Mountain mark the south border. Piquett and East 

Piquett creeks are the main drainages on the east side of the West Fork Bitterroot River (West Fork River),

and Boulder and Baker creeks are the main drainages on the west side (Figure 1-1). There are 

approximately 3,400 acres of private land along the West Fork River. 

The legal description of the Lower West Fork analysis area is:

Township 2 North, Range 21 West, Sections or portions of Sections 27-36, Township 1 

North, Range 20 West, Sections or portions of Sections 6-8, 17-20, 29-32, Township 1 

North, Range 21 West, Sections or portions of Sections 1-30, 34-36, Township 1 North, 

Range 22 West, Sections or portions of Sections 1, 12-15, 23-26, Township 1 South, 

Range 21 West, Sections or portions of Sections 1-4, 10-12, 14-16, 21, 22 Principle 

Meridian Montana, Ravalli County.

The Wildland Fire Risk Mitigation Plan (Community Wildfire Protection Plan; DNRC et al. 2006) 

identifies the Wildland-Urban Interface (WUI) in the Lower West Fork analysis area as high priority for 

fuel reduction. The Wildland Fire Risk Mitigation Plan, developed through a Bitterroot community-based

process, is available on the Internet at www.bitterrootfireplan.info. Priority setting was based primarily on 

forest and fuel conditions, population density, and buildings and other improvements. The Lower West 

Fork Project is designed to respond to goals and objectives of the Community Wildfire Protection Plan, 

National Fire Plan, and the Bitterroot National Forest Plan (Forest Plan). The project is designed to help 

move the project area toward desired conditions described in these plans. Currently, all proposed activities 

occur in Forest Plan Management Areas 1 (Timber Emphasis), 2 (Winter Range Emphasis), and 3a (Partial 

Retention), and 3b (Riparian Emphasis).

This chapter describes the Proposed Action and the Purpose and Need for action. The purpose became 

apparent after comparing the existing conditions in this area with desired conditions, management needs of 

multiple resources, and opportunities to consolidate management actions. Addressing multiple issues in 

one planning process can be more complex than addressing a single issue. For efficiency in management 

and resource allocation, multiple management needs are considered at the same time, in one site-specific 

interdisciplinary planning effort. This effort provides better coordination and integration between resource 

areas in the management and restoration of the forest and a more comprehensive review of cumulative 

effects. 

The Forest Service prepared this final environmental impact statement (FEIS) in compliance with the 

National Environmental Policy Act and other relevant Federal and State laws and regulations. The FEIS 

discloses the direct, indirect, and cumulative environmental effects cause by the proposed action, an 

alternative to the proposed action, and the no action alternative.

1.2 PROPOSED ACTION

A brief overview of the proposed action follows with a more complete description in Chapter 2. 

The proposed action would treat units in and adjacent to the WUI with prescribed fire, and commercial and 

non-commercial thins (Table 1-1). Following commercial thins, the units would be underburned to reduce 
Purpose and Need

1-2 Lower West Fork Project Final EIS 

slash and fuel loads. Approximately 5,056 acres would be treated. Treatments are designed to achieve 

project objectives causing minimal environmental impacts.

The treatment objectives in the commercial thin units would be to reduce stand density, increase the space 

between crowns of the large ponderosa pine, remove ladder fuels, and maintain ponderosa pine as a 

dominant component of the lower elevation, warm, dry sites. 

Most of the prescribed fire treatments would reduce fuel loads in units, except in some higher elevation 

units where moderate intensity burns would be prescribed. The purpose of the moderate intensity burns 

would be to create openings in the late seral stands and promote the regeneration of white bark pine. 

Table 1-1: Proposed Activities in the Lower West Fork Analysis Area

The types of soil, watershed, and fisheries improvement treatments that meet objectives include: 

Ø road realignment, storage, and decommissioning

Ø culvert removal and replacement

Ø installing fish screens on irrigation ditches; 

Ø spot application of gravel at road stream crossings; 

Ø and restoration of soils in terraced units

The Forest Service proposes to decommission approximately 10 miles of road and place 19 miles in longterm storage. Twenty-two culverts would be replaced or removed, 16 of which contribute sediment to 

streams and seven that impede fish passage.

1.3 PURPOSE

The purpose of the Lower West Fork project is to reduce fuel loads in and adjacent to the WUI and 

improve forest resilience to natural disturbance factors such as fire, insects, and disease. The purpose is not 

to prevent insects, disease, and fire from regulating forest conditions but to allow their use without 

threatening human safety or private property. On low elevation, predominantly ponderosa pine sites, 

maintaining lower stand densities reduces competitive stress and improves tree resistance to insects and 

diseases. An additional purpose of this project is to reduce soil compaction on terrace units, and reduce 

siltation and fish barriers created by roads and road crossings. 

The design of the Lower West Fork Project is similar to the Frazier Interface Project (2003), which was 

recently implemented following the collaborative work of the Forest Consensus Council. The Forest 

Consensus Council consists of people with different backgrounds and interests who seek common ground 

and consensus around natural resource issues in the Bitterroot Valley. Additionally, the Lower West Fork 

project complements fuels reduction efforts of the Triple Creek Ranch over the last several years and the 

recent School Point Ecoburn project (2006) to the southwest.

The purpose of this project is to:

1. Reduce fuel loads and lower crown fire hazard in low elevation ponderosa pine/Douglas-fir 

forests

2. Improve forest resilience to natural disturbances (fire, insects, disease); particularly the 

resilience of large diameter ponderosa pine trees 

Proposed Treatment Inside the WUI Outside the WUI

Commercial Thin (acres) 2,671 386

Pre-commercial Thin (acres) 194 102

Prescribed Fire (acres) 1425 278

Road Decommission (miles) 8 2

Road Stored (miles) 7 12

Culverts Replaced or Removed 5 2
Purpose and Need

Lower West Fork Project Final EIS 1-3

Figure 1-1: Vicinity Map of the Lower West Fork Project Area
Purpose and Need

1-4 Lower West Fork Project Final EIS 

3. Maintain or increase shade intolerant species, specifically ponderosa pine

4. Improve overall soil, watershed, and fisheries conditions by reducing road effects and 

rehabilitating degraded soils in historic harvest units on terraced lands.

The goal of this project is to increase wildfire management options beyond fire suppression in the event of 

a fire ignition. It is our intent to reinstate and retain fire as a natural process so it functions at levels that 

shaped these habitats. At the same time, fuel loads can be managed using prescribed fire and natural 

ignitions to protect private property at the interface. Homes burn in wildfires for two reasons: direct 

contact with flames or the heat from flames, or firebrands lofted into the air that land in receptive fuel beds 

(e.g. woodpile, pine needles in the rain gutter, wood shingles, or decks). Hazardous fuel treatments can 

reduce fire behavior, but no treatment eliminates the potential of fire to burn in a given area. Therefore, 

landowners need to reduce fuels on their land and around their homes to minimize the effects of a wildfire. 

More information about making your home “Firewise” can be found at www.firewise.org” (Kootenai NF 

scoping notice).

1.4 NEED 

The differences between current conditions and desired conditions and the effect of those conditions on 

ecosystem processes determined the need for the proposed actions in Lower West Fork analysis area. 

Desired conditions are based on direction and management objectives in the Forest Plan and the 

Community Wildfire Protection Plan. Desired conditions would be open stands of large, early seral tree 

species with low fuel loads in which fire is less likely to transition into the canopy and be carried by the 

crowns. Under these conditions, natural processes would be easier to respond to because insects and 

diseases would be at endemic levels, and fire would be manageable and less likely to require suppression. 

The proposed actions would change the existing resource conditions so they are closer to the desired 

conditions. They would also complement and extend the area of fuels reduction treatments in the Frazier 

Interface project (designed by the Forest Consensus Council), the School Point Ecoburn, and similar 

actions taken on private land. The objective is not to attain a specific desired condition and remain static,

rather to create conditions where natural processes can occur without severe ecological consequences or 

large capital investments. 

Soil, watershed, and fishery resources have residual effects from road system development and past harvest 

practices. This analysis provides an opportunity to evaluate these situations in the context of the planned 

activities and improve these resource conditions. The Water Quality Restoration Plan and Total Maximum 

Daily Loads for the Bitterroot Headwaters Planning Area

1.4.1 REDUCE FUEL LOADS AND LOWER CROWN FIRE HAZARD IN LOW ELEVATION 

PONDEROSA PINE/DOUGLAS-FIR FORESTS

(Restoration Plan) (Montana Department of 

Environmental Quality (MDEQ) 2005) listed the West Fork River as impaired by sediment. Though the 

Restoration Plan did not identify any of the streams in the Lower West Fork analysis area as restoration 

priorities, it recommends that sediment from roads be reduced in the West Fork River Watershed (MDEQ 

2005, pg. 182). Actions needed to improve water quality and fish passage in lower West Fork River, and 

improve soil condition on terraced and harvested lands are discussed and analyzed.

A. Current Condition

The fires of 2000 burned over 307,000 acres on the Bitterroot National Forest (Bitterroot NF). Because of 

their intensity, over 1,000 homes were evacuated, and 70 homes, 170 other buildings, and 94 vehicles

burned. In addition, over 33,000 acres of old growth habitat were destroyed. The fires of 2000 burned a 

portion of the Piquett Creek drainage, but most of the Lower West Fork analysis area did not burn in 2000. 

In 2007, the Rombo fire covered about 29,000 acres and burned 24,700 acres, including much of the upper 

half of the Piquett Creek drainage. The Rombo fire did not pose as great a threat to life and property as the 

fires in 2000 because it started in the higher elevations. However, some areas along the West Fork River 
Purpose and Need

Lower West Fork Project Final EIS 1-5

corridor were evacuated for a day though no homes or structures burned. The suppression cost of this fire 

was 7.2 million dollars. Most of the forests that burned were in Douglas-fir and subalpine fir habitat types. 

Typical fire behavior in most of the area favors high frequency, low intensity fire regimes in lower 

elevations, and mixed-to-high intensity fire regimes above 6,000 ft. Frequent disturbances increased 

variability in vegetative structure. The most substantial changes to stand structure and composition in the 

Lower West Fork analysis area has been the increase of small-to-medium sized, shade tolerant conifers that 

are sensitive to fire. More shade tolerant species in the understory lowers crown base heights and links

surface fuels to crown fuels. The understory crowns act like rungs in a ladder on which surface fire climbs

into the overstory tree crowns. Stands in which fire has been excluded develop multiple layer understories 

of multiple age, shade tolerant tree species. These stands also have higher dead and down fuel loads, which

preheat and ignite the trees with lower crown base heights that then ignite the overstory crowns. The 

increase in ladder fuels presents a high risk of losing the larger overstory trees that previously survived 

many low intensity fires. 

B. Desired Conditions

The Bitterroot Forest Plan guides management by dividing the National Forest into Management Areas. 

The Forest Plan standards for Management Areas 1, 2, 3a, 3b, and 3c (areas suitable for timber 

management) include, “Fuel treatments and site preparation will be coordinated to minimize fire danger 

and insect and disease problems, and secure establishment and protection of new stands” (Forest Plan pgs.

III-7, III-13, III-20, III-28, and III-34). 

Appendix M of the Forest Plan provides direction for Fire Management. Additionally, other Management 

Areas in the analysis area provide direction relative to wildfire protection and fuel management. 

Depending on the management area, fire planning and fuel management are designed to protect and 

enhance timber investments and values, provide big-game winter range habitat, minimize fire danger and 

insect and disease problems, and protect visual quality. The overriding fire management objective on the 

Bitterroot NF is to be prepared and provide suppression and fire use program options that meet 

interdisciplinary goals and move towards desired conditions (USDA 1987, pg. M1-3). The proposed action 

is consistent with this objective.

The desired outcome of fuel treatments is to reduce potential fire intensities while retaining sufficient 

coarse woody debris to maintain soil productivity and provide wildlife habitat. This outcome is not a static 

condition but rather facilitates the occurrence of natural ecosystem processes, such as fire. In the case of 

fire, the desired outcome is to manage either natural ignitions or prescribed ignitions to maintain or 

improve resource conditions. 

The need for change includes:

Reduced Crown Fire Potential: Our objective is to reduce the potential for crown or torching fires and 

retain the use of surface fires to benefit forest resources in the WUI. Low elevation, dry forests in the 

Lower West Fork analysis area developed under and are adapted to frequent, low intensity surface fires.

This fire type also presents less risk to the forest resources and is easier to manage within and adjacent to 

the WUI. Though torching fire behavior kills individual or small clumps of trees, it would be considered 

an improvement over crown fire behavior because fire is not carried by the forest canopy. Crown fires tend 

to replace stands across large areas because they are usually impossible to control until fuel or weather 

conditions change fire behavior. Crown fires also generate hot firebrands that are carried long distances.
Purpose and Need

1-6 Lower West Fork Project Final EIS 

1.4.2 IMPROVE FOREST RESILIENCE TO NATURAL DISTURBANCES (FIRE, INSECTS,

DISEASE), PARTICULARLY THE HEALTH AND RESILIENCE OF LARGE DIAMETER 

(>21” DBH) PONDEROSA PINE TREES;

A. Current Condition

Ponderosa pine communities, in particular, have experienced a shift in composition and structure. Many

different factors have caused these vegetation changes including historic forest management, lack of 

management, and fire suppression. Stand densities have increased which has decreased tree vigor and 

increased fuel continuity. Declining tree vigor increases forest susceptibility to insects and disease, and 

higher tree mortality. Increasing stand density also increases the fuel continuity and provides structure for 

the development of crown fires. Stands in the Lower West Fork project area are a product of succession in 

the absence of disturbance. The over-mature ponderosa pine structure class is not well represented in the 

project area relative to historic conditions. Though data indicates that ponderosa pine remains a principal

cover type on the landscape, Douglas-fir is the dominant component. Stands are structurally similar and 

continuous across the project area. Treating the forest on a landscape scale would improve forest resilience 

to fire, insects, and disease. Treatments emphasize areas of high insect or disease infestation risk and areas 

where it is most effective to develop open ponderosa pine or ponderosa pine/Douglas-fir forests. 

B. Desired Conditions

The mission of the Forest Service is to sustain the health, diversity, and productivity of the Nation’s forests 

and grasslands to meet the needs of present and future generations. One goal of the Forest Plan s is to 

provide sawtimber and other wood products to help sustain a viable local economy (USDA 1987, pg. II-3). 

Another goal is to maintain forest stands so that pest-caused losses are reduced to acceptable levels (USDA 

1987, p. II-4).

The need for change includes:

Improved Forest Resilience: By reducing stocking and fuel loads on low elevation, drier forest sites, the 

Forest Service can improve tree vigor and reduce susceptibility to insects and disease. Tree crown spacing

is also increased and excess surface fuels are reduced, which reduces the potential of extreme fire behavior 

in the event of fire ignition. 

Provide Wood Products and Economic Opportunities: The project would provide job opportunities and 

labor income in the wood products economic sector. Commercial-sized forest products are harvested under 

the proposed action, Alternative 2, and Alternative 3. 

Revenues for Additional Resource Needs:

1.4.3 MAINTAIN OR INCREASE SHADE INTOLERANT SPECIES

 Timber revenues may be available for use to achieve identified 

resource management objectives in the Lower West Fork analysis area.

A. Current Condition

The dry, lower elevations are composed of mixed Douglas-fir and ponderosa pine in well-stocked or overstocked stands with increasing levels of Douglas-fir regeneration in the understory. Lack of fire and past 

management activities have changed forest health, composition, structure, and function in much of the 

project area. Fire suppression initiated the species composition shift in most of the ponderosa pine forest 

type to forest dominated by shade tolerant species such as Douglas-fir and grand fir. Prior to fire 

suppression, fire was an important agent that controlled forest density and species composition. These 

moderately warm, dry grasslands and cool upland sites had high fire frequencies and low to mixed intensity 

fire regimes. Fire suppression has reduced the fire frequency and created conditions for shade tolerant 

species to encroach and out-compete the less shade tolerant species. The mature stands have a dense 
Purpose and Need

Lower West Fork Project Final EIS 1-7

seedling/sapling understory and all cover types in the project area lack structural diversity. Much of the 

area is characterized by dense, homogenous stands of shade tolerant species.

B. Desired Conditions 

To achieve the goal of managing fire consistent with other resource goals, the Forest Service needs to reestablish the fire regime appropriate to the particular ecosystems. The forest composition and structure 

associated with the particular fire regime needs to be restored to control the fire intensity and prevent 

damage to other forest components.

The need for change includes:

Increase the Ponderosa Pine Forest Component: Ponderosa pine was historically a dominant component 

in the warm, dry habitat types. By thinning the units, the Forest Service will open the forest canopy, which

favors ponderosa pine regeneration and retains the mature stand component. Ponderosa pine is well 

adapted to the warm, dry habitat types and when sufficient growing space is available, is resistant to 

insects, disease, and fire. Open forest with a preponderance of ponderosa pine would be resilient to 

environmental changes. 

Reduce Stand Density and Maintain Larger Trees:

1.4.4 IMPROVE OVERALL SOIL, WATERSHED, AND FISHERIES CONDITIONS BY

REDUCING ROAD IMPACTS AND RESTORING SOILS ON TERRACED LANDS IN THE 

AREA.

Forests on warm, dry habitat types were historically 

low density, open stands of shade intolerant tree species such as ponderosa pine and Douglas-fir. Reducing

stand density in the Lower West Fork Area will create more growing space between trees and reduce the 

in-growth of smaller diameter, shade tolerant trees. Basal area (BA) and trees per acre are measures of 

stand density. Ladder fuels, downed woody material, and snags need to be consistent with the structure of 

fire groups represented on the landscape. Reducing stand density and promoting growth on larger diameter 

trees would create forest structure more typical of fire groups in the Lower West Fork analysis area. 

A. Current Condition

The West Fork River is listed as impaired in the Restoration Plan (MDEQ 2005). The impairments are 

sediment and thermal modification. The Restoration Plan identified over 1,700 potential road related 

sediment sources in the West Fork Bitterroot River watershed and recommended reductions in road 

sediment sources. Road sediments reduce water quality and channel conditions by increasing the amount 

of fine sediments in the stream, which settles into the stream substrate, reduces the volume of pools, and 

increases bank erosion. 

Streams and Fish

The fishery is not meeting its desired condition in the Lower West Fork analysis area, primarily because 

several culvert barriers have fragmented bull trout and westslope cutthroat trout populations, and nonnative trout competitors are present throughout the West Fork River and much of Piquett and East Piquett 

creeks. Fish habitat is below its natural potential in most of the streams. The operation of Painted Rocks 

Dam and the West Fork Highway cause most of the habitat impairments on the West Fork River. On the 

Forest, the main impairments are culvert barriers and the encroachment of Forest roads on riparian areas. 

Numerous habitat impairments exist on private lands such as building and road encroachments in riparian 

areas and on streams, reduction of wetted stream perimeters by irrigation withdrawals, and high vegetation 

utilization by grazing livestock. 

Soil conditions in three proposed commercial thinning units are near or exceed Region 1 Soil Quality 

Standards. Rehabilitation such as increasing the amount of fine and coarse wood on the soil for future soil 

Soils
Purpose and Need

1-8 Lower West Fork Project Final EIS 

development, decompacting soils degraded by past ground-based logging operations, or a combination of 

these treatments would improve soil quality. 

The project area contains approximately 297 acres of terrace plantations that were constructed in the late 

1960s to improve tree survival and growth. The construction of terraces created high levels of soil 

disturbance as dozers cut benches across the recently clearcut slopes. The soils cut from the benches were 

side cast down the slope on the risers between benches. Dozer operations created highly compacted soil 

conditions on the terrace benches. Soil monitoring of the terraces indicate these units have 50 to 60 percent 

detrimental soil disturbance, which exceeds Region 1 Soil Quality Standards. 

B. Desired Conditions

Forest Plan management objectives are to manage riparian areas to prevent adverse effects on channel 

stability and fish habitat, maintain populations of catchable trout, and reduce sediment from forest roads. 

Forest Plan standards are to maintain water quality and quantity, protect fish habitat, and reduce sediment 

from roads. In essence, the Forest directs that sediment from forest roads be reduced so streams are 

resilient to natural changes and support beneficial uses including maintaining fish populations.

The objectives of the Region 1 Soil Quality Standards are to manage National Forest under ecosystem 

management principles without permanent impairment of land productivity and to maintain or improve soil 

quality.

The need for change includes: 

Improve Watershed Conditions by Reducing Road/Stream Interactions: Sediment sources are reduced and 

Forest Service management complies with the Restoration Plan. The numbers of sediment contributing 

points on the road system are reduced and no new points are created. 

Maintain Watershed Conditions by Reducing the Potential to Create New Sediment Sources: Ground cover

is maintained so that new erosion sources are not created. Disturbed areas are seeded, fertilized, and 

mulched when needed to grow or maintain vegetation on a site and prevent erosion. Drainage structures, 

straw bales, and other mitigation measures are in place to prevent sediment input during log hauling.

Improve the Fishery by Reconnecting Fragmented Streams and Reducing Road Impacts: Fish move freely 

between the West Fork River and its tributaries at any time of the year, with no man-made barriers to

movement. Non-native trout species are absent or found at such low numbers that they have a negligible 

impact on bull trout and westslope cutthroat trout populations. High channel complexity (particularly in 

the form of abundant large woody material and pools), stable stream banks, clean substrates, and cold water 

temperatures characterize fish habitat in the West Fork and its tributaries. Road impacts on riparian areas 

are reduced to the lowest extent possible. On private lands, irrigation withdrawals have negligible impacts

on wetted perimeters, water temperatures, and fish movement. All ditches are screened to prevent fish 

entry.

Improve Soil Conditions Through Active Rehabilitation:

1.5 MEASURES OF SUCCESS

 Degraded soil conditions in past harvest units and

terrace plantations are actively rehabilitated to improve soil compaction levels, organic matter content, 

nutrient cycling, and soil microbial communities. Rehabilitation of compacted soils in past harvest units 

and on terrace benches achieves the desired condition through treatments that break up compaction, provide 

surface organic matter, and revegetate previously impacted areas with native understory vegetation. 

In order to compare how well the alternatives meet the purpose and needs identified for this project, 

measures of success were identified and analyzed. These measures give an indication of whether the 

alternative moves conditions toward the desired conditions. The measurements listed in Table 1.2 are used 
Purpose and Need

Lower West Fork Project Final EIS 1-9

to compare how the proposed action and alternatives to the proposed action would meet the project purpose 

and need (Section 1.3).

Table 1-2: Measurements for Meeting the Lower West Fork Purpose and Need

1.6 FOREST PLAN MANAGEMENT AREAS

The Forest Plan details management direction for Bitterroot NF resources by Management Areas (MA). 

MAs 1, 2, 3a, 3c, 3b, 5, 6, 7c, 8 and 9 are included in the Lower West Fork analysis area (USDA Forest 

Service 1997) (Fig. 1-2). Timber harvest, pre-commercial thins, and prescribed fire are proposed in MA 1, 

2, 3a, and 3b. A brief description of the goals of each management area is provided below.

MA-1 (22%): Emphasize timber management, livestock and big game forage production, and access for 

roaded dispersed recreation activities. Assure minimum levels of visual quality, old growth, and habitat for 

other wildlife species.

MA-2 (24%): Optimize elk winter range habitat using timber management practices. Emphasize access 

for mineral exploration and roaded dispersed recreation activities. Provide moderate levels of visual 

quality, old growth, habitat for other wildlife species, and livestock forage.

MA-3a (18%): Maintain the partial retention visual quality objective and manage timber. Emphasize 

roaded dispersed recreation activities, old growth, and big game cover. Provide moderate levels of timber, 

livestock forage, big game forage, and access for mineral exploration.

MA-3b (4%): Manage riparian areas to maintain water quality and water-related recreation activities. 

Emphasize water and soil protection, dispersed recreation use, visual quality, and old growth. Provide low 

levels of timber harvest, livestock forage, and big-game forage on fisheries riparian areas, and moderate 

levels on non-fisheries riparian areas. Restrict road construction to meet water quality and fish objectives. 

MA-3c (1%): Maintain the retention visual quality objective and manage timber. Emphasize dispersed 

recreation activities that will enhance the use of adjacent developed recreation sites and wilderness, and not 

degrade old growth, big game cover, and fish. Provide low levels of timber harvest, livestock forage, and 

big game forage. Limit road density as necessary to meet visual objectives but provide access, as needed, 

for mineral exploration.

MA-5 (12%): Emphasize motorized and non-motorized semi-primitive recreation activities and elk 

security. Manage big-game winter range to maintain or enhance big-game habitat.

Purpose and Need Measurement Indicators

Reduce fuel loads and lower crown fire hazard in 

low elevation ponderosa pine/Douglas-fir forests. Area of reduced potential fire behavior

Improve forest resilience to natural disturbances 

(fire, insects, and disease) particularly in large 

diameter ponderosa pine.

Area of reduced stand density

Employment contribution

Income contribution

Revenue available for other resource work

Maintain or increase shade intolerant species.

Area of ponderosa pine habitat treated

Area of reduced stand density

Area of reduced Fire Regime Condition Class

Improve overall soil, watershed, and fisheries 

conditions by reducing road impacts and restoring 

soils on terraced lands in the area.

Miles of road decommissioned

Number of stream crossings improved or removed

Number of fish barriers removed

Area of soil improvement in past harvest units

Area of soil improvement on terrace plantations
Purpose and Need

1-10 Lower West Fork Project Final EIS 

MA-6 (3%): Manage to maintain existing wilderness characteristics and potential for inclusion in the 

wilderness system. No project activities are proposed in this MA.

MA-6, 9 (2%): Manage to meet direction for both MA 6 and MA 9.
Purpose and Need

Lower West Fork Project Final EIS 1-11

Figure 1-2: Management Areas (MAs) in the Lower West Fork Analysis Area
Purpose and Need

1-12 Lower West Fork Project Final EIS 

MA-8a (8%): Manage at the minimum level for elk security, old growth, and habitat diversity; but protect 

timber, soil, water, recreation, range, and wildlife resources on adjacent management areas. 

MA-9 (1%): Manage to retain the examples of outstanding old growth forest representing several habitat 

types, both upland and riparian (USDA 1991, page 15). Maintain the high water quality of Boulder Creek. 

Maintaining the fire-dependant old-growth forest featuring ponderosa pine requires special attention in 

contrast to the fire-sensitive old-growth spruce-fir and grand fir forests that require fire suppression for 

their maintenance (USDA. 1991, page 16)

1.7 SITE-SPECIFIC FOREST PLAN AMENDMENT

Implementing portions of the Lower West Fork proposed action would require a site-specific amendment to 

the Forest Plan (1987). Therefore, the action alternatives include an amendment that would modify the 

following Forest Plan standards:

Ø Winter range thermal cover standard

Ø Elk habitat effectiveness standard

Ø Coarse woody debris standard

The proposed amendment would only apply to the Lower West Fork project. 

A. Winter Range Thermal Cover

The site-specific winter range thermal cover standard for the Lower West Fork project would read:

Proposed Standard

“Thermal cover on winter range will be treated in the Lower West Fork analysis area

to the extent needed to protect the overstory from loss due to fire.”

This proposed site-specific amendment recognizes and addresses the conflicting nature of the Forest Plan’s 

fuels and fire protection goals, objectives and standards for the WUI and the overlapping winter range 

thermal cover standard defined in the Forest Plan Record of Decision (1987, pg. 8). Research conducted 

since the Forest Plan was signed questions the necessity of thermal cover for survival of wintering elk 

(Cook, et al. 1998). Researchers found “no significant, positive effect of thermal cover on the condition of

elk during any of the six experiments. In contrast, dense cover provided a costly energetic environment,

resulting in significantly greater over-winter mass loss, fat catabolism, and (in one winter) mortality.” 

Wintering elk survived and retained body weight better in open areas than in thermal cover. For this 

reason, whether thermal cover is necessary for individual elk survival or elk population viability seems 

open to question. For additional information, refer to Chapter 3, Section 3.8.5.C.

Discussion

B. Elk Habitat Effectiveness

The Forest Plan standard for elk habitat effectiveness (EHE) states, “Manage roads through the Travel Plan 

process to attain or maintain 50 percent or higher elk habitat effectiveness (Lyon 1983) in currently roaded 

third order drainages.” In five third order drainages, EHE is below Forest Plan standards. Though EHE 

can be improved in some of these drainages, it will not achieve the standard because of the steep terrain the 

roads traverse and the open roads are needed to access trailheads. 

The elk habitat effectiveness (EHE) standard that would only apply to the Lower West Fork project would 

be: 

Proposed Standard

All roaded 3rd order drainages in the Lower West Fork analysis area will attain 

or maintain 50 percent or higher elk habitat effectiveness (Lyon 1983) except 
Purpose and Need

Lower West Fork Project Final EIS 1-13

in five drainages. Elk habitat effectiveness will be maintained or improved in 

the five 3rd order drainages as shown below:

Elk Habitat Effectiveness in Five 3rd Order Drainages in the Lower West Fork Analysis Area

This proposed site-specific amendment recognizes that the EHE standard is not currently being met in five, 

3rd order drainages in the Lower West Fork analysis area. The roads proposed for storage or 

decommissioning in these third order drainages improves EHE in 02e424-1, 02f427-3, and 02h450-2 but 

they do not change EHE in 02h449-1 and 02i450-1 (Table 1-3). EHE cannot be met in02e424-1, 02h449-1, 

or 02i450-1 drainages because the open roads in each of these drainages access trailheads. In 02h450-2 and 

02f427-3, the open roads are needed for forest management purposes.

Discussion

C. Coarse Woody Debris

The site-specific coarse woody debris standard to be applied for the Lower West Fork project on all 

affected lands would read:

Proposed Standard

“To maintain soil productivity and wildlife habitat while meeting the purpose and need

of fuel reduction, coarse woody debris (material greater than 3 inches in diameter) will 

be left from designated leave trees, snags, logs, and breakage of limbs and tree tops 

that occur during harvest at or above the minimum levels identified below. Material 

will be evenly distributed on each acre. Minimum levels will also be retained after 

prescribed fire treatments. Fire Groups are described in the FEIS, Chapter 3, Section 

3.3.3 C.

Wood larger than 15 inches in diameter will not be intentionally ignited during hand lighting. It is 

understood that once the fire is lit by hand crews, the fire may burn into large coarse woody debris and 

combust various pieces.”

Proposed Coarse Woody Debris Standard by Fire Group

Since the Forest Plan was signed, research indicates the recommended amount of coarse woody debris 

varies by habitat type (Graham et al. 1994; Brown et al. 2000). Current research provides guidelines that

are more refined to meet the Forest Plan goals and objectives. The amounts prescribed in the Forest Plan 

are sometimes contradictory (i.e. 10 to 15 tons) with the amounts recommended by Graham et al. (1994)

and Brown et al. (2000) and may require fuel loads that are too high for low elevation, dry ponderosa pine 

Discussion

3rd Order Drainage

02e424-1

Elk Habitat Effectiveness 

43 %

02f427-3 47 %

02h449-1 43 %

02h450-2 44 %

02i450 -1 48 %

Fire Group

2, 4

Coarse Woody Debris

5-10 tons/acre

6 10-20 tons/acre

7, 8, 9 8-24 tons/acre
Purpose and Need

1-14 Lower West Fork Project Final EIS 

sites. Heavy amounts of coarse woody debris increase the potential fire intensity. High amounts of coarse 

woody debris should not be left in stands of the Lower West Fork analysis area unless required for sitespecific soil rehabilitation treatments such as the terrace units, non-commercial thin units, and Unit 1, a 

commercial thin unit. 

For additional information on this amendment, please refer to Appendix F.

1.8 PROJECT SCOPE

1.8.1 GEOGRAPHIC, TEMPORAL, AND ADMINISTRATIVE SCOPE

Section 40 CFR 1508.25 of the NEPA implementing regulations provides guidance determining the proper 

scope of an EIS. The geographic scope of the project is displayed in Figure 1-1 and is generally described 

in the introduction (Section 1.1). The temporal scope for the project would be the period of

implementation, which the ID Team assumes would be 10 years. This assumption is reasonable because

some of the identified activities depend on funds other than revenues generated by the proposed 

commercial treatments. This time frame incorporates the time to submit funding proposals, and complete 

project designs. 

The Administrative Scope of the project includes the analysis of the Proposed Action (Alternative 2), one

alternative to the proposed action (Alternative 3), and the No Action Alternative (Alternative 1). The No 

Action Alternative reflects the current status and administrative activities within the analysis area.

The Proposed Action includes those activities necessary to fulfill the identified purpose and need, as well as 

all connected actions as described in Chapter 2. The activities necessary to meet the purpose and need of 

the project include prescribed burning, tree removal, and road improvement projects. Actions connected to 

the commercial element of the purpose and need include temporary road construction, work on existing 

roads, slash burning, and all mitigation measures and design criteria described in Chapter 2. The resource 

opportunities identified in Chapter 2 are not connected actions, because they could be implemented 

independently from the other actions (40 CFR 1508.25). 

The direct, indirect, and cumulative effects are considered in the analysis, pursuant to 40 CFR 1508.7 and 

40 CFR 1508.8, and are disclosed in Chapter 3. Direct effects are caused by the action. They occur at the 

same time and place as the action. Indirect effects are also caused by the action but occur later in time or

farther from the action location. Effects can be beneficial or detrimental. The direct and indirect effects of 

the alternatives were analyzed for all resources at issue or as required by law.

A cumulative effect is the impact on the environment resulting from the incremental effect of the action 

when added to other past, present, and reasonably foreseeable actions. The past, present, and foreseeable 

projects considered in the cumulative effects analyses are listed in Appendix B. The size of the area needed 

to analyze cumulative effects differs by resource. The cumulative effects area for many resources is limited 

to the project area itself. Some resources, however, like water, need a larger area of review, including land 

outside of the analysis area. The list of activities in Appendix B applies to the largest cumulative effects 

area for any resource. Each specialist reviewed the list and analyzed the actions that might influence their 

resource, within the cumulative effects area appropriate for that resource. The effects discussions, 

including the potential cumulative effects, of the alternatives in the Lower West Fork project are in Chapter 

3. 

1.8.2 DECISION TO BE MADE

This FEIS is not a decision document. It is a document disclosing the environmental consequences of 

implementing the different alternatives, including the No Action Alternative. There was a 45-day public 

comment period after completion of the DEIS. The ID Team considered public comments as they prepared 

the FEIS. The Responsible Official documents the decision in a Record of Decision based on information 

in the final environmental impact statement, project file, and public comments. 
Purpose and Need

Lower West Fork Project Final EIS 1-15

The responsible Federal official is the Bitterroot National Forest Supervisor. The decision will consider: 

Ø Whether to treat the Forest at this time, and if so, what areas to treat, what treatment methods 

would be implemented, and what mitigation and monitoring would be required. 

Ø Whether to conduct watershed improvement work at this time, and if so, what areas to treat, 

and what methods and monitoring would be implemented.

Ø Whether to treat unit 70 in the Research Natural Area and what studies or monitoring to 

implement that would document the results. 

1.8.3 FEIS ORGANIZATION

The FEIS contains four chapters, including this one.

Chapter 1 describes the purpose and need for the proposed action, the parameters of the analysis, and the 

decision to be made. 

Chapter 2 describes and compares the alternatives the Forest Service considered in the Lower West Fork

project. It includes a discussion of how alternatives were developed, an overview of mitigation measures, 

monitoring, and the features common to all alternatives. Also included are a description and map of each 

alternative considered in detail, and a comparison of these alternatives focusing on measures of success for 

meeting the purpose and needs and issues. Chapter 2 presents the alternatives in comparative form 

providing the decision maker and public a clear basis for choice between options.

Chapter 3 describes the affected physical, biological, social, and economic environments of the project area 

and summarizes the effects of implementing each alternative on those environments. It also presents the 

scientific and analytical basis for the comparison of alternatives presented in the comparison tables in 

Chapter 2.

Chapter 4 contains the public comments the ID Team received on the Draft EIS and their responses to 

them. 

The list of Best Management Practices; past, present and future foreseeable activities; literature cited;

glossary; list of preparers; and Forest Plan amendment analyses follow Chapter 4 as appendices. 

The Project File contains public comments on the proposed action, analytical reports, and additional 

information and maps that support discussions in this FEIS. In places in these documents, a Project File 

(PF) document is referenced, for example (PF-SCOPE-001).
Alternatives

Lower West Fork Project Final EIS 2-1

CHAPTER 2.0

ALTERNATIVES

2.1 INTRODUCTION

This chapter describes and compares the alternatives considered in the Lower West Fork analysis area. It 

includes a discussion of how alternatives were developed and a description and map of each alternative 

considered in detail. It also includes an overview of mitigation and monitoring measures, and features 

common to all alternatives. Chapter 2 is intended to present the alternatives in comparative form providing 

a clear basis for choice among options for the decision maker and the public.1

The information used to compare alternatives in Section 2.7 of this Chapter is summarized from Chapter 3, 

“Affected Environment and Environmental Consequences.” Chapter 3 contains the detailed discussions, 

based on current science, of the environmental consequences of each of the alternatives. It provides the 

basis for the indicators of how the alternatives meet the purpose and need. 

 Comparison of these 

alternatives includes a comparison of activities, a comparison of measures of success for meeting the 

purpose and needs, and a comparison of effects based on identified issues.

The numbers contained in this Chapter and Chapter 3 are approximations, not absolute. The variability in 

natural systems defies precision but the processes used to evaluate the systems are the same, and the 

numbers that represent these processes have relative values for comparing effects. 

2.2 ALTERNATIVE DEVELOPMENT AND DESCRIPTIONS

The Interdisciplinary Team (ID Team) analyzed and used the information gathered through scoping to 

develop alternatives to the proposed action. Many of the issues and comments received during scoping 

were addressed through project design and mitigation of effects. The Proposed Action (Alternative 2), the 

No-Action alternative (Alternative 1), and an additional action alternative (Alternative 3) are analyzed in 

detail and provide a reasonable range of alternatives to achieve the purpose and need for the project. 

2.2.1 PUBLIC PARTICIPATION

The Council on Environmental Quality (CEQ) defines scoping as ``...an early and open process for 

determining the scope of issues to be addressed and for identifying the significant issues related to a 

proposed action'' (40 CFR 1501.7). The scoping process invites public participation to help identify issues 

with the project, and obtain public comment at various stages in the planning process. Scoping is an 

interactive process that continues until a decision is made. In addition to the following specific activities, 

the Lower West Fork Project has been listed on the Bitterroot National Forest quarterly Schedule of 

Proposed Actions since January 2007 (PF-PUB-INV-007, 008). That schedule is made available to many 

individuals, groups, and agencies. The public has been invited to participate in the project in various ways, 

as described below. 

On October 13, 2006, the Forest Service sponsored a field trip to the Frazier Interface (2003) project area to 

review accomplishments and discuss their application to developing a proposal for the Lower West Fork 

Project (PF-PUBLIC-005). Three landowners, three Forest Consensus Council members, three local 

media, four industry representatives, one environmental group representative, and five representatives from 

the Forest Service attended. The Lower West Fork Project concept was introduced and compared to the 

Frazier Interface project. The group discussed progress on the Frazier Interface project and the Forest 

Service received feedback from those in attendance.

Field Trips

 1 40 CFR 1502.14
Alternatives

2-2 Lower West Fork Project Final EIS 

The Forest Service sponsored another public field trip on May 16, 2007 (PF-PI-001, 006). Four Forest 

Service employees and two members of the timber industry attended. Participants visited representative 

treatment sites and discussed potential silvicultural treatments and the feasibility of harvest in current 

economic conditions

A field trip with members of the Bitterroot Restoration Committee (BRC) was held on January 16, 2008. 

The purpose of the field trip was to familiarize the group with the Lower West Fork Project purpose and 

need and to compare it with the restoration principles adopted by Montana Forest Restoration Committee. 

The group viewed the project from a vantage point at Triple Creek ranch and discussed it during lunch at 

the Trapper Creek Job Corps center. 

Following the October 2006 field trip, the interdisciplinary team (ID Team) developed the Proposed Action 

and published a legal notice in the Ravalli Republic newspaper on March 7, 2007 (PF-Scoping-07-002). 

This notice provided details on the project and invited people to comment during the 30-day scoping 

period. News releases on the project proposal appeared in the Ravalli Republic on March 8, 2007. The 

Forest Service mailed a scoping letter, with four maps describing the proposed project and its background, 

to about 148 people, organizations, and agencies on March 7, 2007. They were invited to submit comments 

and questions on the project proposal by April 7, 2007. The Forest Service received 12 responses (PFScoping-001-009, 021, 023, 031). On March 10, 2007, the Forest Service established a Lower West Fork 

Project webpage providing public access to scoping letters, maps, and examples of treatments used in the 

proposed action and alternatives. This website was updated as new information became available 

(

Local News Media, Public Mailing, and Internet Website Media

www.fs.fed.us/r1/bitterroot).

Preliminary ID Team analysis indicated that larger areas needed treatment to better apply current research 

and meet the project’s purpose and need of reducing crown fire risk on a landscape scale. In addition, the 

Rombo fire burned through several previously proposed units. Three of these units were proposed for 

prescribed fire, two for commercial harvest, and two for non-commercial thins. Only one of these units, a 

non-commercial thin unit would still benefit from treatment. The proposed action was expanded to treat 

additional areas within the analysis area boundary and a Notice of Intent was published on December 12, 

2007. The Notice of Intent opened another comment period that closed January 22, 2008. The Forest 

Service received 10 comments during this period. These comments in addition to the comments received in 

the initial comment period were used to identify issues and develop alternatives to the proposed action. 

The Draft Environmental Impact Statement (Draft EIS)was completed and a Notice of Availability was 

published in the Federal Register on April 10, 2009. The Notice of Availability opened the 45-day 

comment period that ended May 26, 2009. The Forest Service sent letters to 154 individuals, 

organizations, and agencies informing them that the Draft EIS was available as a document, compact disc, 

or on the Bitterroot National Forest web site. They also placed a legal advertisement in the Ravalli 

Republic, the newspaper of record, and distributed articles to the Missoulian, Missoulian on line, the 

Ravalli Republic, and the Bitterroot Star. The Forest Service received six letters in response to these 

notifications and the comments in the letters were used to correct mistakes or clarify the analysis. The ID 

Team added another alternative to evaluate the effects of stand treatments without the use of fire but did not 

carry that alternative through the analysis. The responses to all the comments the Forest Service received 

are in Chapter 4. 

Public Meetings

Prior to the January 16, 2008 field trip, District Ranger Campbell briefed the BRC on the project at a 

regularly scheduled meeting on December 18, 2007. The purpose and need for management and the BRC 

restoration principles were compared as part of the briefing. The BRC was also briefed on the project 

status at the regularly scheduled meeting on October 27, 2008.
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Lower West Fork Project Final EIS 2-3

2.2.2 ISSUES

The ID Team reviewed all comments received through scoping for specific information and issues relevant 

to the Lower West Fork Project proposal. The resource areas for which comments were made and how 

they are used in the analysis are listed in Table 2-1. The key issues are those that tie to the Purpose and 

Need and drive alternative development. Analysis issues and comments relate to the resource effects of the 

proposed management actions or alternatives to the proposed actions. The ID Team evaluates these issues 

in the effects analysis or mitigate them through the project design. Other comments or issues not 

specifically relevant to the proposed action or purpose and need for this project are not addressed in this 

analysis. 

The key issues are fuel reduction in and adjacent to the Wildland-Urban Interface (WUI), reducing forest 

stand density to promote growth on large ponderosa pine, and reducing sedimentation in tributaries of 

lower West Fork River. 

Table 2-1: Resource Issue Areas Identified During Scoping and Their Use in the Lower West Fork 

Analysis

Issue Addressed Project 

Purpose and Need

Drove Alternative 

Development Addressed or Analyzed in DEIS

Soils No No Effects analyzed in Chapter 3. Resolved 

through project design and mitigations

Noxious Weeds No No Effects analyzed in Chapter 3. Resolved 

through project design and mitigations 

Old Growth No No Effects analyzed in Chapter 3. Resolved 

through project design and mitigations

Snags No No Effects analyzed in Chapter 3. Resolved 

through project design and mitigations

Sediment, water quality, Yes Yes Effects analyzed in Chapter 3. Resolved 

through project design and mitigations

Cumulative effects of past 

management No No

Effects analyzed in Chapter 3 for each 

resource as appropriate. Resolved 

through project design and mitigations

Fuel treatments in the WUI Yes Yes Addressed by development of Alternative 

3

Forest vegetation 

management Yes Yes Addressed by development of Alternative 3

Rombo fire (effects and fuel 

break) No Yes Addressed by development of Alternative 3

Roadless area boundary No No

Issue not analyzed in detail. Already 

determined by regulation and the Forest 

Plan.

Boulder Creek RNA No No Effects analyzed in Chapter 3. Resolved 

through project design and mitigations

Prescribed burning (air 

quality, visuals, burn 

intensity)

No No Effects analyzed in Chapter 3. Resolved 

through project design and mitigations

Economics No No Effects analyzed in Chapter 3. Resolved 

through project design and mitigations

Utilization of small 

trees/thinning/basal area 

goals

No No Effects analyzed in Chapter 3. Resolved 

through project design and mitigations

Road access/ Travel 

Management No No Effects analyzed in Chapter 3. Resolved through project design and mitigations
Alternatives

2-4 Lower West Fork Project Final EIS 

Public and internal scoping was used to identify key issues of the Lower West Fork Project. Similar issues 

were combined into one statement where appropriate. The key issues and indicators used to evaluate how 

they are addressed by the alternatives are described below. How each alternative addresses the key issues 

is discussed under the alternative descriptions later in this chapter.

Key Issues

Some commenters question the need for fuel reduction on National Forest. They suggest fuel reduction is 

only effective within a few tens of meters of a home. Some commenters are skeptical that thinning stands 

would reduce crown fire potential and believe it would increase the rate of fire spread and thereby increase 

exposure of people, and ecosystem components and processes to fire. Other commenters support fuel 

reduction but believe that logging should not be used to reduce fuels. Still others who support fuel 

reduction believe timber harvest and slash removal should be used but not prescribed fire. 

Key Issue: Fuel Treatments in the WUI

The following issue indicators are evaluated for each of the alternatives:

Ø Changes in potential fire type 

Ø Area treated in the WUI

Some commenters expressed skepticism about the motives for the project. They suspect an underlying 

motive to promote timber growth and generate timber harvest volume more than reducing fuel hazards. 

They believe logging will disrupt the natural forest succession and recovery.

Key Issue: Forest Vegetation Management 

Others believe that tree densities should be lower than currently practiced to offset potential site conditions 

created by climate change. They advocate basal areas between 40 and 60 square feet per acre (ft2

/ac) on the 

lower elevation, drier sites and 60-80 ft2

/ac on the more moist sites. Still others believe logging is the 

preferred way to remove excess biomass and finance the chipping of small diameter wood for use in the 

creation of bio-fuel and other forms of energy. They recognize broadcast burning as unavoidable but 

consider burning piled fuels as unnecessary.

The following issue indicators are evaluated for each of the alternatives:

Ø Area of commercial thin treatments

Ø Area of commercial thin treatments in the WUI

Ø Potential commercial volume harvested

Some commenters are concerned about potential logging impacts on soils (erosion, compaction, and 

displacement), watersheds (erosion and sediment) and fish (silt in streams). The following issue indicators 

are evaluated for each of the alternatives:

Key Issue: Sediment and Water Quality 

Ø Soil productivity

Ø Reduction in long-term deposition of road sediment into streams

Ø Removal of fish barriers at road crossings of streams

A. Alternative Development Process

Each action alternative represents a site-specific proposal developed through interdisciplinary evaluation of 

current and desired conditions, and is based on field verification. The ID Team also uses topographic 

maps, aerial photos, and resource data to identify units and design treatments. The alternatives provide 

different responses to the key issues; one alternative may respond to more than one issue. Each action 

alternative is also designed to at least partially meet the purpose and need for action and move toward the 

desired conditions described in Chapter 1. 
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Lower West Fork Project Final EIS 2-5

The alternatives considered in this analysis represent a reasonable range of approaches to meet the purpose 

and need in the project area. The Responsible Official may, at the time of the decision, select an action 

alternative but modify it by substituting one or more of the different actions or methods included in a 

different alternative.

B. Alternatives Considered in Detail

The No Action alternative (Alternative 1), Proposed Action (Alternative 2), and one other alternative are 

considered in detail. No activities other than what is already occurring would occur under Alternative 1. 

The other alternatives present different ways of satisfying the purpose and need by responding with 

different emphases to the key issues discussed above. 

Areas, distances, mapped unit boundaries, and other measures describe the alternatives and are based on the 

best available information. Not all of the information was precisely measured in the field. There may be 

some differences between estimates and field measurements when the Forest Service lays out the project. 

Because of the variability of existing conditions in proposed activity units, treatments are not expected to 

occur on every acre within every unit. For example, if the spacing of larger trees in parts of units currently 

meets the desired condition; the only treatment would be to slash and hand-pile smaller trees and underburn 

the unit. The estimated net proposed harvest acreage within each activity unit is provided in the tables that 

accompany each of the alternatives. Changes that occur between planning and implementation would be 

within the resource parameters analyzed in this document. If changes are outside of the analysis 

parameters, the ID Team will re-analyze that portion of the project or it will be removed from the project. 

2.2.3 ALTERNATIVE 1 (NO ACTION)

This alternative represents the existing condition and baseline data against which the other alternatives are 

compared. Under the No Action alternative, current management plans would continue to guide 

management of the project area. Work that is ongoing or previously planned within the project area would 

also continue under this alternative.

None of the proposed actions, fuel reduction, timber harvest, road improvements, decommissioning, 

storage, or culvert removals would occur. Fires, insect activity, and existing motorized recreation use 

would continue. 

The No Action alternative is required by regulation (40 CFR 1502.14d). The analysis for the No Action 

alternative in Chapter 3 and the comparison of alternatives in Section 2.2.7 describe the possible

consequences of not managing the area as proposed in the action alternatives. 

The No Action alternative responds in the following ways to the key issues:

Key Issue Response

Need for and Effectiveness of Fuel Hazard Reduction. This alternative would not conduct any fuel 

reduction work using either logging or prescribed fire.

Management of Forest Vegetation. No units would be commercially thinned and there would be no 

temporary roads, skid trails, or tracked line machine (TLM) trails created to support the harvest. Noncommercial thinning would not occur at this time under this decision. 

Impacts on Soil, Watersheds, and Fisheries. Roads would not be decommissioned or stored as part of this 

analysis or decision. Fish barrier culverts would not be replaced or eliminated. Fuel reduction and forest 

thinning would not occur. 

2.2.4 ALTERNATIVE 2 (PROPOSED ACTION)

Under Alternative 2, the Forest Service would reduce fuels on approximately 5,056 acres using commercial 

thinning, non-commercial thinning, and prescribed fire (Table 2-2). These treatments would reduce the 
Alternatives

2-6 Lower West Fork Project Final EIS 

fuels in the areas between the School Point Ecoburn and Frazier Interface projects (Fig. 2-1). They would 

also break up fuels on the lower ends of the Piquett and Violet creek drainages. Approximately 84% of the 

treatment areas would occur in the WUI (Fig. 2-1, 2-2). About 2,493 acres would be commercially thinned 

using ground-based and skyline yarding systems (Table 2-2). Commercially thinned units would be 

underburned following harvest. Excess slash resulting from harvest may need to be piled and burned prior 

to the underburn unless markets for small diameter wood are available. Fuels would be reduced on another 

1,704 acres using prescribed fire only. Most of the prescriptions would be low intensity fire except in units 

32, 33, and the upper elevations of unit 61A, which would be treated with mixed intensity fire. About half 

of the units would need to have trees in the understory felled (manual slashing) prior to ignition to create an 

even fuel bed and prevent the fire from moving into the tree crowns. 

Non-commercial thinning would occur on about 296 acres of existing plantations to provide more growing 

space for the trees. Fire would not be prescribed in these units since tree crowns are still close to the 

ground. Slash would be “lopped and scattered” to expedite its decay and prevent wood boring beetle 

infestations. 

Table 2-2: Unit Treatments Under Alternative 2

Unit 

No. Treatment* Area(acre)

WUI 

Area 

(acre)

Yarding Method (acre) Temp. 

Roads1

(ft)

TLM2

Trail (ft2) Ground Skyline TLM

1 Commercial Thin with underburn 239 239 129 (Winter) 26 31 1,246 404

2 Commercial Thin with underburn 197 197 76 104 0 N/A3 N/A

3 Commercial Thin with underburn 163 163 98 58 7 N/A 873

4 Commercial Thin with underburn 142 142 52 0 0 N/A N/A

5 Commercial Thin with underburn 35 35 12 21 0 N/A N/A

6 Commercial Thin with underburn 35 35 35 0 0 N/A N/A

7 Commercial Thin with underburn 25 25 0 9 10 N/A N/A

8 Commercial Thin with underburn 130 130 43 62 25 1,454 1,035

9 Commercial Thin with underburn 109 109 16 62 15 1,284 N/A

10 Commercial Thin with underburn 55 55 11 40 0 N/A N/A

11 Commercial Thin with underburn 33 33 30 3 0 N/A N/A

12 Commercial Thin with underburn 125 125 93 13 19 1,863 598

13 Commercial Thin with underburn 84 84 7 77 0 N/A N/A

14 Commercial Thin with underburn 19 0 3 16 0 N/A N/A

15 Commercial Thin with underburn 38 0 3 35 0 N/A N/A

16 Commercial Thin with underburn 45 45 5 40 0 1,077 N/A

18 Commercial Thin with underburn 36 36 0 24 0 N/A N/A

19 Commercial Thin with underburn 51 51 39 12 0 N/A N/A

20 Commercial Thin with underburn 32 32 4 0 28 546 556

21 Commercial Thin with underburn 18 0 0 18 0 N/A N/A

22 Commercial Thin with underburn 17 0 0 17 0 N/A N/A

23 Commercial Thin with underburn 8 0 0 8 0 N/A N/A

24 Commercial Thin with underburn 19 0 19 0 0 N/A N/A

25 Commercial Thin with underburn 7 0 2 5 0 N/A N/A

26 Commercial Thin with underburn 6 2 4 2 0 N/A N/A

27 Non-commercial Thin 4 0 0 0 0 N/A N/A

28 Commercial Thin with underburn 16 0 0 16 0 N/A N/A

29 Commercial Thin with underburn 55 55 9 46 0 N/A N/A

32 Prescribed Fire 131 131 N/A N/A N/A N/A N/A

33 Prescribed Fire 282 237 N/A N/A N/A N/A N/A

34 Commercial Thin with underburn 119 119 43 0 0 N/A N/A

35 Commercial Thin with underburn 35 35 5 0 31 N/A 1,814

40 Commercial Thin with underburn 13 13 0 13 0 N/A N/A
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Lower West Fork Project Final EIS 2-7

Unit 

No. Treatment* Area(acre)

WUI 

Area 

(acre)

Yarding Method (acre) Temp. 

Roads1

(ft)

TLM2

Trail (ft2) Ground Skyline TLM

41 Commercial Thin with underburn 121 121 9 0 105 528 109

42 Commercial Thin with underburn 51 51 8 39 0 N/A N/A 

60 Commercial Thin with underburn 140 0 102 28 0 1,322 N/A

60A Prescribed Fire 31 0 N/A N/A N/A N/A N/A

61 Commercial Thin with underburn 418 418 131 145 8 2,112 1,812

61A Prescribed Fire 414 415 N/A N/A N/A N/A N/A

62 Commercial Thin with underburn 66 66 19 47 0 N/A N/A

63 Prescribed Fire 20 20 N/A N/A N/A N/A N/A

63B Prescribed Fire 32 32 N/A N/A N/A N/A N/A

64 Prescribed Fire 246 246 N/A N/A N/A N/A N/A

65 Prescribed Fire 40 28 N/A N/A N/A N/A N/A

66 Prescribed Fire 171 2 N/A N/A N/A N/A N/A

68 Commercial Thin with underburn 162 162 27 0 0 N/A N/A

69 Prescribed Fire 27 27 N/A N/A N/A N/A N/A

70 Prescribed Fire 199 199 N/A N/A N/A N/A N/A

71 Prescribed Fire 70 49 N/A N/A N/A N/A N/A

72 Prescribed Fire 4 4 N/A N/A N/A N/A N/A

73 Prescribed Fire 2 2 N/A N/A N/A N/A N/A

74 Prescribed Fire 4 4 N/A N/A N/A N/A N/A

75 Non-commercial thin 20 0 N/A N/A N/A N/A N/A

80 Non-commercial thin 24 0 N/A N/A N/A N/A N/A

81 Commercial Thin with underburn 25 25 0 25 0 N/A N/A

82 Non-commercial thin 11 11 N/A N/A N/A N/A N/A

83 Non-commercial thin 14 14 N/A N/A N/A N/A N/A

84 Non-commercial thin 2 2 N/A N/A N/A N/A N/A

85 Non-commercial thin 15 15 N/A N/A N/A N/A N/A

86 Commercial thin 23 23 0 23 0 N/A N/A

87 Non-commercial thin 38 38 N/A N/A N/A N/A N/A

88 Commercial Thin with underburn 30 29 7 24 0 N/A N/A

89 Commercial Thin with underburn 61 0 0 51 10 N/A 1,046

90 Commercial Thin with underburn 38 0 3 36 0 N/A N/A

91 Non-commercial thin 28 28 N/A N/A N/A N/A N/A

92 Non-commercial thin 27 0 N/A N/A N/A N/A N/A

93 Non-commercial thin 12 0 N/A N/A N/A N/A N/A

94 Non-commercial thin 7 7 N/A N/A N/A N/A N/A

95 Non-commercial thin 43 43 N/A N/A N/A N/A N/A

96 Non-commercial thin 23 23 N/A N/A N/A N/A N/A

97 Non-commercial thin 4 4 N/A N/A N/A N/A N/A

98 Non-commercial thin 11 0 N/A N/A N/A N/A N/A

99 Commercial Thin with underburn 16 16 0 0 16 N/A 927

100 Prescribed Fire 30 30 N/A N/A N/A N/A N/A

101 Non-commercial thin 9 9 N/A N/A N/A N/A N/A

102 Non-commercial thin 4 0 N/A N/A N/A N/A N/A

TOTALS 5,056 4,290 1,044 1,083 366 11,432 9,174

PERCENTAGES 85 424 44 14 (2.2 mi) (1.7 mi) 1

 Some temporary roads and tracked line machine trails provide access to units but are not completely in the unit. However, they 

are included in the total distance for the unit. 2 TLM: Tracked line machine; 3 NA: Not Applicable; 4 Percent of harvest area;
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2-8 Lower West Fork Project Final EIS 

Approximately 2.2 miles of temporary road and 1.7 miles of tracked line machine (TLM) trail would be 

constructed to access timber. Individual lengths of road or trail vary between 100 and 2,100 feet (Table 2-

2). TLM trail requires level pads, 20 by 20 feet at 125-150 foot intervals, on which the line machine 

stands. 

TLM pads are usually built along a ridge where access is easy and timber can be cabled up to the ridge. 

TLM trails may require occasional excavation in spots to level steep side slopes and ensure safe machine 

travel. Temporary roads and TLM trails would be restored to natural contours following their use (pg. 2-

17).

Almost 19 miles of road would be stored and another 10 miles would be decommissioned (Fig.2-1, 2-2). 

Twenty-two culverts would be removed at road-stream crossings, 16 of which deliver sediment to streams 

and two that block fish passage. Storing or decommissioning 11.6 miles of road would be mandatory 

mitigation to off-set short-term timber sale effects. This mitigation would remove 15 culverts, 11 of which

contribute sediment to streams (Table 2-3). The remaining roads that are not mitigation would be 

decommissioned or stored with appropriated or partnership funds.

Table 2- 3: Mandatory Stewardship Road Treatments Under Alternative 2

On open roads, five culverts that block fish passage would be replaced with fish-passable structures as 

funding is available. Soil rehabilitation would occur in proposed commercial thinning units (1, 3, and 12) 

to improve soil quality in areas with historic soil compaction as directed by the Region 1 Soil Quality 

Standards. Also, soil restoration would occur on about 297 acres of terrace plantations after the units are 

thinned. 

No more then 300 acres would be treated with herbicide annually for about ten years. Areas that may be 

treated include roads proposed for decommissioning or storage, haul routes, temporary roads, TLM paths, 

and landings. Skid trails and openings created by the treatments within units may also be sprayed if posttreatment monitoring indicates weeds are encroaching. Approximately 1,400 acres located throughout the 

project area may require treatment over the ten year period. About 200 of those acres occur along roads, 

landings or TLM paths. 

Fuel reduction would decrease the potential for stand replacing crown fires and enhance options for using 

fire to fulfill its natural function on the landscape. Some of the prescribed fire units would require slashing 

of ladder fuels prior to fire ignition. Slashing the unmerchantable understory would prevent fire from 

moving into the tree crowns. In some areas where the slash levels are too high for a low intensity fire, the 

excess slash would be piled and burned prior to igniting the understory burn. Note: Markets that would use 

small diameter wood are under development. If these markets are available at the time of treatment, the 

excess slash may be sold to those markets. Periodic understory burning and thinning would also occur in 

the future to maintain desired vegetation and fuel conditions. All fuel reduction activities would occur in 

Forest Plan MAs 1, 2, 3a, 3b, and 9.

Fuel Reduction 

Road Number Watershed Treatment Length (miles)

13411 East Piquett Storage 0.8

13411 East Piquett Decommission 0.4

13434 Piquett Storage 2.7

13457 East Piquett Storage 1.8

13466 Pierce Storage 0.6

13830 Violet Storage 1.6

13831 Violet Decommission 1.3

13836 East Piquett Decommission 2.4

13837 Piquett Repair sediment sources

74321 Piquett Repair sediment sources
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Lower West Fork Project Final EIS 2-9

Commercial Thinning (approximately 3,056 acres; units 1-16, 18-26, 28, 29, 34, 35, 40-42, 60-62, 68, 81, 

86, 88-90, 99)

Commercial thinning would occur in units that have understory trees of merchantable size. These units 

would be thinned from below leaving an open stand of predominantly large ponderosa pine. Trees 7 inches 

diameter breast height (DBH) and greater are merchantable and would be thinned from these units. Large 

trees may also be harvested to achieve the desired crown spacing. Not every acre of every commercial thin 

unit will be commercially thinned. Some parts of the units are inaccessible to logging equipment, have 

inclusions of non-commercial size trees, or have special resource conditions that prevent logging. The 

Forest Service anticipates about 2,493 acres would be commercially thinned. However, the entire units 

would also be non-commercially thinned and underburned following timber harvest (Table 2-2). 

Timber harvest would occur through either timber sale contract or forest stewardship contracts or 

agreements. Forest stewardship contracts or agreements allow the Forest Service to trade goods for 

services. Revenue from the sale of timber would be available to fund, at least in part, other activities that 

do not generate revenue such as soil rehabilitation and road decommissioning. The use of timber sale funds 

reduces reliance on appropriated funds to achieve resource management objectives. 

Commercial thinning within the project area would:

Ø thin the overstory from below and remove potential ladder fuels 

Ø maintain a desired stocking level and provide more growing space for early seral tree species, 

primarily ponderosa pine

Ø maintain the large tree component in the overstory 

Ø break up the homogenous and continuous horizontal and vertical structures 

Ø reduce the presence of less fire-tolerant vegetation

Ø change the stand composition by increasing fire-tolerant vegetation 

Approximately 25 to 60% of the standing vegetation would be removed in the proposed thinning units. 

Vegetation Response Units (VRUs) are groupings of stands with similar habitat types. VRUs allow us to 

interpret the response of vegetation to natural disturbance processes and anticipate future landscape 

conditions. VRUs 1, 2, and 3 are generally warm and dry sites. The forest is typically open stands of 

ponderosa pine and Douglas-fir. The Douglas-fir component varies with VRU; VRU 3 has a higher 

component of Douglas-fir than VRUs 1 and 2. The natural fire intervals are generally 5-25 years on these 

sites which helps maintain the grassy understory and the ponderosa pine overstory. Fires at this frequent 

interval tend to be low intensity, though mixed intensity fires occur at 15 to 45 year intervals on the cooler, 

moist sites within these VRUs. After the high fuel loads are reduced, there would be less risk associated 

with managing unplanned ignitions at the typical time of year. 

VRUs 7, 8, and 9 are cool, more moist sites. They tend to be higher elevation sites except for VRU 8, 

which is associated with riparian areas and wetlands. These units have dense stands of Engelmann spruce, 

subalpine fir, lodgepole pine, and Douglas-fir, and smaller representation of alpine larch and whitebark 

pine. The fire interval is generally longer than 100 years and tend to be stand replacing fires, though low 

and mixed intensity fires occur.

Within VRU 1, 2 & 3 basal area would average 60 ft2/ac, varying between 40 and 80 ft2/ac depending on 

site capability. Small openings (2-5 acres) would be created in areas of dense, shade tolerant regeneration 

that would be unlikely to survive understory burning. Within sensitive watersheds, these openings would 

be reduced to about a quarter acre in size. Overall, the Forest Service expects there would be a balanced 

mix of ponderosa pine and Douglas-fir remaining in the unit after treatment. The units would also contain 

a mix of diameter classes and trees would be well spaced. The long term goal of this treatment is to 

maintain a range of age classes, create openings for regeneration, and adjust for accretion and tree mortality 

by allowing trees space to grow into different size classes. The residual trees would be the larger, more fire 

resistant trees with thicker bark and higher base crown levels. 
Alternatives

2-10 Lower West Fork Project Final EIS 

Within VRU 7, 8, and 9

Following thinning and the treatment of logging slash, an understory burn would be prescribed. Existing 

surface fuel loads and activity fuels would be reduced through a combination of yarding, piling and 

burning, and prescribed fire. Understory tree density and ladder fuels would be reduced through slashing 

where necessary to facilitate underburning and protect individual larger trees from scorch. Reducing 

surface fuels using prescribed fire and mechanical methods reduces the probability that the overstory would 

ignite in a wildfire (Graham et al. 2004). 

VRU 9 makes up most of the area. Stand density would average 80-140 ft2/ac 

basal area and vary with site capability. Stocking would be reduced approximately 30 to 60 percent. The 

species mix on cool moist sites would be lodgepole pine, spruce, and subalpine fir. Douglas-fir and 

lodgepole pine would be more common on the lower and mid-elevation sites. Merchantable trees of poor 

vigor or competing with better quality trees would be removed. Trees would be thinned from below to 

reduce stand density, focusing on removing trees in the understory before removing the larger trees in the 

overstory. Declining lodgepole pine would be removed, thereby creating openings for regeneration. 

Lodgepole pine is a short-lived, seral species that does not respond well to partial harvest. The lodgepole 

pine on these sites is often infested with dwarf mistletoe or mountain pine beetle.

Timber would be logged using ground-based and skyline systems. Ground-based systems would be used 

on slopes less than 35% and would include wheeled or tracked equipment that raises the forward end of 

logs when skidding. Skyline systems would be used on steeper slopes with a cable stretched between the 

skyline machine tower and a fixed anchor (typically a stump or base of a tree). A carriage travels along the 

cable and suspends either the front end of the log or the entire log off the ground during transport from the 

woods to a landing. A traditional skyline system would yard wood to a landing located on a road. An offroad skyline yarder, or tracked line machine (TLM), would be used to access steep ground that cannot be 

reached from a system road or temporary road. A TLM trail would be designated and logs would be 

yarded to a landing located on the trail. From the TLM landing, logs would be moved by a ground-based 

skidder to a main landing for processing and/or loading on a truck. Table 2-2 specifies the logging systems 

for each harvest unit in the alternative. 

Logging Systems

Prescribed Burning (approximately 1,700 acres; units 32, 33, 60A, 61A, 63, 63B, 64-66, 69, 71-74, 100)

Low intensity prescribed fire would reduce surface fuels but would not consume the soil duff layer. About 

20% tree mortality would be expected in the small diameter trees but stocking levels would not change 

appreciably. Moderate intensity prescribed fires create openings up to 25 acres in the stand and consume 

more of the ground fuels. Some localized areas of duff would be consumed where heavy concentrations of 

fuels exist. Low intensity prescribed fires are planned for all prescribed fire units except Units 32, 33, and 

the upper part of Unit 61A. Moderate intensity fires would be prescribed in these units to create openings 

for regeneration. 

Prescribed burning recycles nutrients back into the soil that are then available for uptake by residual trees. 

Within VRUs 1-3, slashing material less than 7 inches DBH and the removal of duff or slash from large 

residual trees, especially ponderosa pine, may be needed to protect these trees from being killed by the 

prescribed fire. Slashing before igniting the burn would minimize the radiant heat that could damage 

overstory trees. 

Noncommercial Thinning (approximately 296 acres; units 27, 75, 80, 82-85, 87, 91-98, 101, 102) 

Noncommercial thinning is proposed in predominately ponderosa pine plantations. These plantations have 

high densities of naturally regenerated species, including Douglas-fir and lodgepole pine, mixed with 

planted ponderosa pine. Trees growing within 12-18 feet of saplings designated as crop trees would be cut 

and lopped with chainsaws, leaving approximately 150-200 trees per acre. Crop trees are defined as 

dominant, vigorously growing trees with the best form. In areas with dwarf mistletoe-infected Douglas-fir 

overstory and an understory of predominantly Douglas-fir, the infected overstory trees would be girdled 
Alternatives

Lower West Fork Project Final EIS 2-11

and left as snags during thinning. Many of the infected understory Douglas-fir would also be removed, 

which would create openings within these young stands. Stand density would be reduced by 30 to 60 

percent in the thinning units.

All Ground-Based Units and Swing trails in Skyline Units (Units 1, 3, and 12; and Terrace Units 14, 21, 

25, 27, 35, 81, 86, 88, 89, 90, and 99)

Soil Treatments 

Main skid trails (those with detrimental soil compaction) in ground-based units and swing trails in skyline 

units used would be decompacted following commercial thinning activities. Units 1, 3, and 12 have levels 

of detrimental disturbance from historic logging that are near or exceed the Region 1 Soil Quality 

Standards. In units 3 and 12, areas with historic detrimental disturbance would be decompacted in addition 

to the decompaction of skid trails used during the project. Subsoiling is required in these units even if 

winter ground-based operations are utilized in order to create a net improvement in soil productivity in 

these units. A subsoiling grapple rake (SGR) or excavator mounted subsoiler that achieves the desired 

decompaction results would be use to decompact the soils (Soils Section 3.5). The soil rehabilitation 

activities in these units would create a net improvement in soil quality following timber harvest and would 

enhance and support natural soil restoration processes.

Legacy compaction is also present in the lower part of Unit 1. However, these soils are not conducive to 

subsoiling treatments because of the high coarse rock fragment content. Therefore, ground-based yarding 

in this part of unit 1 (approximately 65 acres below FS road 363) would occur during winter conditions to 

minimize further soil disturbance. Standard winter timber operating procedures would be required to yard 

this unit. Commercial thinning operations would be required to limb and leave tops in this 65-acre area. 

Woody debris levels would range between 15 and 20 tons/acre following thinning to enhance natural soil 

rehabilitation. Higher levels of woody debris would enhance the development of organic soil horizons, 

microbial populations, and other soil functions essential to restoring pre-disturbance conditions.

Soil rehabilitation in the terrace units would focus on terrace benches where soil compaction and surface 

disturbances are the greatest. The majority of terrace units in the project area have steep slopes (> 35%) 

that are not suitable or safe for ground-based equipment necessary to complete active soil decompaction 

treatments with a subsoiler or ripper. As an alternative treatment, vegetation in steep terrace units will be 

hand felled and removed commercially with skyline yarding systems or through hand piling and prescribed 

burning. Vegetation treatments will meet silvicultural prescriptions provided in section 3.2. The 

treatments will be required to leave 10 to 15 tons/acre of woody debris specifically on the terrace benches 

for soil rehabilitation. Achieving this woody debris specification may require some leaving limbs and 

treetops in these units. Woody debris levels on the risers between benches would adhere to guidelines 

displayed in Table 3.5-5. Increased woody debris on the terrace benches will increase soil moisture and 

improve soil biological activity which will also accelerate natural soil recovery processes to alleviate 

compaction. 

In terrace units where slope gradients are less than 35 percent, vegetation may be removed with groundbased yarding systems. Following ground-based yarding the terrace benches may be subsoiled or ripped to 

break up compaction. Ripping may occur on these areas as an alternative to subsoiling due to the high 

amount of soil mixing already present on the terrace benches. In this case, additional soil mixing by 

ripping would not create adverse soil conditions. An organic fertilizer would be applied following 

subsoiling or ripping on the terrace benches to improve soil organic concentrations, nutrient cycling, and 

microbial populations. Woody debris would be placed on terrace benches following these treatments at a 

rate of 10 to 15 tons/acre. The preferred method of revegetating the site is to allow native vegetation 

growing on the risers between the benches to encroach and establish on the benches. However, the Forest 

Service would seed a mixture of native grasses and forbs if weed establishment is probable. The 

establishment of native, understory plants would enhance soil building on the terrace benches and foster 

soil condition improvement over time.
Alternatives

2-12 Lower West Fork Project Final EIS 

Noxious weeds would be sprayed with herbicides on logging haul roads, roads accessing prescribed burn or 

thinning units, TLM paths, temporary roads, landings, and roads proposed for decommissioning or storage. 

These areas total about 200 acres. In addition, noxious weeds would be sprayed where they encroach 

within units. Monitoring following timber harvest, thinning, and burning treatments would determine the 

potential treatment areas. The ID Team estimates that 30% of a unit occurring in VRUs 1, 2, or 3 

(Silviculture section Chapter 3) would be potential treatment areas. VRUs 1, 2, and 3 are the most 

susceptible to noxious weed infestations because they are warmer, drier sites. See PF-NOX-004 for details 

on units, roads, temporary roads, and TLM paths that may need herbicide treatments. 

Herbicide Treatments 

Most of the potential treatment area, about 1,400 acres, would only be treated if monitoring determines that 

noxious weeds are encroaching into treatment areas. It is likely that some of these areas would require 

herbicide treatments but the risk of further spread would be reduced by catching new infestations early. 

Terraced units are more likely to need herbicide treatments since there would be more ground disturbance 

associated with decompacting soils. 

In addition to the proposed herbicide treatments analyzed in the Lower West Fork Project area, there are 

areas on the west side of the project area that have already been analyzed for herbicide treatments in the 

Selway Bitterroot Wilderness Invasive Plants Management Project DEIS (USDA Forest Service 2008d). 

Units and roads that are covered in that analysis are identified in a Lower West Fork spreadsheet (PF-NOX004). 

This alternative responds to the following key issues:

Key Issue Response

Need for and Effectiveness of Fuel Hazard Reduction. Fuels would reduced on 5,056 acres on both sides 

of the West Fork River using commercial thins, non-commercial thins, and prescribed fire.

Management of Forest Vegetation. Almost 2,500 acres would be commercially thinned and would require 

2.2 miles of temporary roads and 1.7 miles of TLM trails. Non-commercial thinning would occur on 296

acres (Fig. 2-1, 2-2). 

Impacts on Soil, Watersheds, and Fisheries. Almost 19 miles of road would be stored and 10 miles 

decommissioned. These treatments would remove 22 culverts at road-stream crossings, 16 of which 

deliver sediment to streams and two that block fish passage. Five culverts that block fish passage on open 

roads would be replaced with fish passable structures (Fig. 2-1, 2-2). Soil treatments would reduce 

compaction on about 297 acres of terraced plantation as in Alternative 2.

2.2.5 ALTERNATIVE 3

Alternative 3 was developed in response to public comments that the Rombo Fire had reduced fuel loads in 

the upper Piquett Creek drainage and fuel treatments were not needed to modify crown fire behavior in the 

WUI on the east side of the West Fork River. Alternative 3 responds to this issue by dropping all the 

commercial thin and prescribed fire treatment units on the east side of the West Fork River, except for 

treatments in the terraced plantations. The ID Team retained these treatments because reducing compaction 

in the terraced units would restore soil productivity and reduce the area of detrimental soil disturbance. On 

the west side of the West Fork River, commercial thin treatments would only occur inside the WUI. 

Prescribed fire and non-commercial thins would extend beyond the WUI boundary. The treatments 

prescribed in Alternative 3 would be the same as described in Alternative 2. Unit 60 is the only unit on the 

west side of the river that would not be treated because it is outside of the WUI. Alternative 3 responds to 

four categories of issues:

Ø Soil, sediment, and water quality

Ø WUI treatments
Alternatives

Lower West Fork Project Final EIS 2-13

Ø Forest treatments to restore or maintain resilience

Ø Rombo fire effects.

Under Alternative 3, the Forest Service would reduce fuels on approximately 3,302 acres using commercial 

thinning and prescribed fire (Table 2-4). On the west side of the river, treatments and treatment units 

would be the same as in Alternative 2, except Unit 60 would not be treated. Approximately 91% of the 

treatment areas would occur in the WUI (Fig. 2-3, 2-4). About 2,091 acres would be commercially thinned 

using ground-based and skyline yarding systems (Table 2-5). Fuels would be reduced on another 1,139 

acres using prescribed fire only. 

About 296 acres in existing plantations would have non-commercial thins. 

Approximately 1.5 miles of temporary road and 1.6 miles of TLM trail would be constructed to access 

timber. Individual road or trail segments vary between 404 and 2,112 feet. 

Table 2- 4: Unit Treatments Under Alternative 3

Unit 

No. Treatment* Area(acre)

WUI Area 

(acre)

Yarding Method (acre) Temp. 

Roads (ft)

TLM1

Ground Skyline TLM Trail (ft)

1 Commercial Thin with underburn 239 239 64 26 31 1246 404

2 Commercial Thin with underburn 197 197 76 104 0 N/A N/A

3 Commercial Thin with underburn) 163 163 98 58 7 N/A 873

4 Commercial Thin with underburn 142 142 52 0 0 N/A N/A

5 Commercial Thin with underburn 35 35 12 21 0 N/A N/A

6 Commercial Thin with underburn 35 35 35 0 0 N/A N/A

7 Commercial Thin with underburn 25 25 0 19 10 N/A N/A

8 Commercial Thin with underburn 130 130 43 62 25 1454 1035

9 Commercial Thin with underburn 109 109 16 62 15 1284 N/A

10 Commercial Thin with underburn 55 55 11 40 0 N/A N/A

11 Commercial Thin with underburn 33 33 30 3 0 N/A N/A

12 Commercial Thin with underburn 125 125 93 13 19 1863 598

14 Commercial Thin with underburn 19 0 3 16 0 N/A N/A

21 Commercial Thin with underburn 18 0 0 18 0 N/A N/A

25 Commercial Thin with underburn 7 0 2 5 0 N/A N/A 

27 Non-commercial Thin 4 0 N/A N/A N/A N/A N/A

32 Prescribed Fire 131 131 N/A N/A N/A N/A N/A

33 Prescribed Fire 282 237 NA N/A N/A N/A N/A

34 Commercial Thin with underburn 119 119 43 0 0 N/A N/A 

35 Commercial Thin with underburn 35 35 5 0 31 N/A 1,814

60A Prescribed Fire 31 0 N/A N/A N/A N/A N/A 

61 Commercial Thin with underburn 418 418 131 145 8 2112 1812

61A Prescribed Fire 414 414 N/A N/A N/A N/A N/A

62 Commercial Thin with underburn 66 66 19 47 0 N/A N/A

63 Prescribed Fire 20 20 N/A N/A N/A N/A N/A

63B Prescribed Fire 32 32 N/A N/A N/A N/A N/A

70 Prescribed Fire 199 199 N/A N/A N/A N/A N/A

75 Non-commercial thin 20 0 N/A N/A N/A N/A N/A

80 Non-commercial thin 24 0 N/A N/A N/A N/A N/A

81 Commercial Thin with underburn 25 25 0 25 0 N/A N/A 

82 Non-commercial thin 11 11 N/A N/A N/A N/A N/A

83 Non-commercial thin 14 14 N/A N/A N/A N/A N/A

84 Non-commercial thin 2 2 N/A N/A N/A N/A N/A

85 Non-commercial thin 15 15 N/A N/A N/A N/A N/A

86 Commercial thin with underburn 23 23 N/A 23 0 N/A N/A
Alternatives

2-14 Lower West Fork Project Final EIS 

Unit Treatment* Area WUI Area Yarding Method (acre) Temp. TLM1

87 Non-commercial thin 38 38 N/A N/A N/A N/A N/A

88 Commercial Thin with underburn 30 29 7 24 0 N/A N/A

89 Commercial Thin with underburn 61 0 0 51 10 N/A 1046

90 Commercial Thin with underburn 38 0 3 36 0 N/A N/A

91 Non-commercial thin 28 28 N/A N/A N/A N/A N/A

92 Non-commercial thin 27 0 N/A N/A N/A N/A N/A

93 Non-commercial thin 12 0 N/A N/A N/A N/A N/A

94 Non-commercial thin 7 7 N/A N/A N/A N/A N/A

95 Non-commercial thin 43 43 N/A N/A N/A N/A N/A

96 Non-commercial thin 23 23 N/A N/A N/A N/A N/A

97 Non-commercial thin 4 4 N/A N/A N/A N/A N/A

98 Non-commercial thin 11 0 N/A N/A N/A N/A N/A

99 Commercial Thin with underburn 16 16 0 0 160 N/A 927

100 Prescribed Fire 30 30 N/A N/A N/A N/A N/A

101 Non-commercial thin 9 9 N/A N/A N/A N/A N/A

102 Non-commercial thin 4 0 N/A N/A N/A N/A N/A

TOTALS 3,599 3,277 743 798 172 7,959 8,509

PERCENTAGES 91 432 48 9 1.5 mi 1.6 mi

1 TLM: Tracked line machine 2 Percent of harvest area

Under Alternative 3, about 18 miles of road would be stored and 27 miles decommissioned (Table 3.6-13). 

Thirty-three culverts would be removed from road-stream crossings, 23 of which contribute sediment to 

streams. Storing or decommissioning 11.8 miles of road would be mandatory mitigation to off-set shortterm timber sale effects. This mitigation would remove 18 culverts, 12 of which contribute sediment to 

streams (Table 2-4). The remaining roads would be decommissioned or stored with appropriated or 

partnership funds. The same culverts blocking fish passage would be removed or replaced as described in 

Alternative 2. 

Table 2- 5: Mandatory Stewardship Road Treatments Under Alternative 3

Non-commercial thin units were retained in Alternative 3 because they are plantations created by previous 

harvest, their treatment doesn’t influence crown fire behavior, and treatment would support the investments 

made when they were established. Non-commercial thins would occur on the same units as in Alternative 

2 on approximately 296 acres.

Changes Made Since the Draft EIS

The prescription for the 65 acre portion of unit 1 with detrimental soil disturbance was modified to address 

the concern that tractor-based yarding equipment would intensify soil compaction. The ID Team

Road Number Watershed Treatment Length (miles)

13411 East Piquett Storage 0.8

13411 East Piquett Decommission 0.4

13424 Piquett Decommission 2.9

13457 East Piquett Storage 1.8

13466 Pierce Storage 0.6

13830 Violet Storage 1.6

13831 Violet Decommission 1.3

13836 East Piquett Decommission 2.4

13837 Piquett Repair sediment sources
Alternatives

Lower West Fork Project Final EIS 2-15

developed an adaptive management protocol that would reduce ladder fuels, provide coarse woody debris, 

and increase crown spacing. Initially, the area would be thinned from below and the slash would be lopped 

and scatterred to prevent beetle infestation. The slash would be left on the ground at least one year so that 

nutrients would leach into the soil. The slash would be burned and the area would be re-surveyed to assess 

residual coarse woody debris on the site. The coarse woody debris goal is 15-20 tons per acre. If 

monitoring indicates residual coarse woody debris is below the required level, larger trees would be felled 

and left on site. Thinning the larger trees would emphasize felling Douglas-fir and retaining ponderosa 

pine. Douglas-fir logs greater than 17 inches diameter and longer than six feet are preferred as coarse 

woody debris because Douglas-fir decays at a slower rate than ponderosa pine and would stay on the soil 

surface longer. This thinning would increase crown spacing and the larger diameter components of coarse 

woody debris. Limbs and treetops may needed to be piled and burned if the fine fuel load increases the 

potential for high fire intensity.

The parameters and factors governing fuel reduction and therefore the treatment objectives and methods 

would be the same as those described in Alternative 2.

Fuel Reduction 

Commercial Thinning: approximately 1,702 acres; units 1-12, 14, 21, 25, 34, 35, 61, 62, 81, 86, 88-90, 99

Prescribed Burning: approximately 1,139 acres; units 32, 33, 60A, 61A, 63, 63B, 70, and 100

Soil rehabilitation would occur in the same commercial thin and terrace units as in Alternative 2. The 

portion of Unit 1 with high detrimental soil disturbance would not be commercially thinned but would be 

thinned thinned from below and underburned to accelerate nutrient recycling and soil building. 

Soil Treatments 

Alternative 3 responds to the following key issues:

Key Issue Response

Need for and Effectiveness of Fuel Hazard Reduction. Alternative 3 would reduce fuels on about 3,302 

acres using commercial thins and prescribed fire treatments on the west side of the West Fork River only 

(Fig. 2-3). No treatments would occur on the east side of the West Fork River except in terrace units (Fig. 

2-4). Terrace units would be treated the same as in Alternative 2 but because these units are relatively 

small, they would have little effect on changing fire behavior. 

Management of Forest Vegetation. Almost 1,702 acres would be commercially thinned and would require 

1.5 miles of temporary roads and 1.6 miles of TLM trails. Non-commercial thins would occur on 296

acres. 

Impacts on Soil, Watersheds, and Fisheries. Almost 19 miles of road would be stored and 27 miles 

decommissioned (Fig. 2-3, 2-4). Thirty-three culverts would be removed from road-stream crossings, 23 of 

which deliver sediment to streams and two that block fish passage. On open roads, five culverts that block 

fish passage would be replaced with fish passable structures. Soil treatments would reduce compaction on 

about 297acres of terraced plantations as in Alternative 2.

2.2.6 COMPARISON OF ALTERNATIVES

Tables 2-6 and 2-7 display relative differences between the alternatives in meeting the Lower West Fork 

Project Purpose and Need (Table 2-6) and the amount and types of treatments (Table 2-7). Since no 

activities are proposed in Alternative 1, the No Action alternative, the zero values represent no change in 

the parameters at this time resulting from human activity. The forest will continue to change in the absence 

of human activities and the effects of these changes are analyzed in Chapter 3.
Alternatives

2-16 Lower West Fork Project Final EIS 

Table 2- 6: Comparison of Measures to Meet the Purpose and Need of the Lower West Fork Project

Purpose and Need Measure Alt. 1 Alt. 2 Alt.3

Area of reduced fire behavior (acres) 0 1,336 892

Area of reduced stocking (acres) 0 2,789 1,998

Area of reduced forest structure change1 (acres) 0 2,493 1,702

Area of ponderosa pine treated 0 2,614 1,829

Area treated in the WUI 0 4,290 3,277

Employment contribution ($) 0 170 121

Income contribution ($) 0 5.6 million 4.0 million

Revenue available for resource improvement ($) 0 140,000 100,000

Expected funding needed for mandatory activities ($) 0 581,000 493,000

Reduced long-term sedimentation (tons/year) 0 27 39

Decommissioned roads (miles) 0 10 27

Stored roads (miles) 0 19 19

Stream crossings removed 0 23 33

Fish barriers eliminated 0 7 7

Soil rehabilitation in terraced plantations (acres) 0 297 297

Soil rehabilitation in units with historic disturbance (acres) 0 32 85

Represents area of commercial thin treatments. Though non-commercial thin treatments reduce stocking, they do not change the 

structure of the unit.

Table 2- 7: Comparison of Activities Connected to Vegetation Treatments for All Alternatives

Activity Alt. 1 Alt. 2 Alt. 3

Total Number of Treatment Units 0 76 51

Treatments in the WUI (acres) 0 4,290 (85%) 3,277 (91%)

Commercial Thin in the WUI (acres) 2671 (87%) 1,948 (93%)

Proposed Treatments in acres (% of total)

 Commercial Thin with underburn 0 3,056 (60%) 2,092 (58%)

 Prescribed Burn only 0 1704 (34%) 1212 (34%)

 Non-commercial Thin 0 296 (6%) 296 (8%)

 Research 0 1991 (4%) 199 (6%)

Total Acres Treated 5,056 3,599

Yarding Systems (acres)

 Skyline 0 1,449 (58%) 959 (54%)

 Tractor 0 1,044 (42%) 743 (46%)

Temporary Road Construction (miles) 0 2.2 1.5

Tracked line machine Trail (miles) 1.7 1.6

Road Decommision and Storage (miles) 0 29 46

Estimated Timber Harvest Volume (million board 

feet,MMBF) 0 7.5 5.1

1

 This is the RNA treatment unit that would have research level monitoring to assess the treatment outcomes.

2.2.7 ALTERNATIVES CONSIDERED BUT ELIMINATED

The ID Team considered six other alternatives to the Proposed Action but eliminated them from detailed 

analysis. These alternatives were suggested in comment letters the Forest Service received in 2007 and 

2008 in response to scoping notices and during the comment period between the draft EIS and final EIS.
Alternatives

Lower West Fork Project Final EIS 2-17

This alternative was not considered in detail because it would treat fuels on only a tiny fraction of the 

National Forest. The effects of this alternative would be indistinguishable from the No Action alternative. 

This alternative would not meet the purpose and need because it would not:

Focus fuel treatments in the home ignition zone rather than extensive wildland fuel 

management.

Ø Reduce fuel loads enough to lower crown fire hazard

Ø Improve ponderosa pine resilience

Ø Promote shade intolerant trees species representation in the stands. 

This alternative is addressed adequately in Alternative 2 and 3. The Roads Analysis process was used to 

determine which roads are not needed for future management. The cost of fixing all roads that cause soil 

and water problems is disclosed in the FEIS. The arterial roads that encroach on streams in the analysis 

area (Roads 363 and 5630 along Pierce and Lavene creeks, for example) have been graveled to reduce 

sediment production, and short of paving or relocation, little more can be done to reduce sediment 

production. Paving or relocation is infeasible due to topographic constraints and high costs.

Remove or fix all roads that cause soil and water problems, or are not needed for future 

management.

None of the treatment units were proposed exclusively for forest health reasons, or for generating money. 

All of the treatment units were designed to improve stand resiliency to fire and insect activity. Therefore, if 

all of the units proposed to improve stand resiliency were dropped, the alternative would be the same as the 

No Action alternative, which is analyzed.

Drop all units where treatments are proposed for forest health reasons, or for generating 

money to do other work.

This alternative is adequately addressed by Alternatives 2 and 3. Both alternatives propose the use of 

prescribed fire in inventoried roadless areas, and neither alternative proposes commercial harvest in 

inventoried roadless areas.

Do not include any commercial logging in roadless areas, but do include the use of 

prescribed fire.

Alternative 3 was developed in response to this recommendation. Watershed restoration elements are also 

included in Alternative 2. 

Develop a watershed restoration alternative, or at least include watershed restoration 

elements in all of the reasonable alternatives.

The effectiveness of mechanical thinning for reducing passive and active crown fire potential is dependent 

on the type of harvest system used, and the activity fuels remaining after harvest (Stephens et al. 2009). 

Whole tree harvest systems cause little increase in 1-, 10-, and 100-hour fuels while cut-to-length systems 

greatly increase surface fuels in these burn classes. Stephens et al. (2009) found that mechanical treatments 

followed by prescribed burning or pile burning were the most effective treatment for reducing crown fire 

potential and predicted tree mortality. Post-wildfire studies have found that stands treated mechanically 

with no surface fuel treatments burned with higher intensity than those where mechanical treatments were 

followed by prescribed fire (Skinner et al. 2004, Cram et al. 2006, Schmidt et al. 2008). 

Reduce fuels through timber harvest and slash disposal without the use of prescribed fire or 

pile burning.

Slash could be ground into chips, which would require whole tree yarding. The nearest market is 100 miles 

from the analysis area and is a limited option at this time. Also, chip vans have wider turning radius than 
Alternatives

2-18 Lower West Fork Project Final EIS 

typical log trucks and may not be able to access some units. Under Alternatives 2 and 3, chipping is an 

option if the market is available and the units are accessible (pg. 2-8, 2-14). 

This alternative would not treat the prescribed fire only units, which would maintain pathways by which 

fire could threaten resources in and adjacent to the WUI. It would not reduce fuel loads adequately and 

may increase fuel loads in some situations. Therefore, it would not meet the purpose of reducing fuel loads 

and lowering crown fire hazard. Not treating the prescribed fire units would decrease the fuels 

management effectiveness at the landscape-level (Arno and Fiedler 2005, Finney et al. 2005).

2.3 MITIGATION MEASURES AND PROJECT DESIGN

The Forest Service designs projects and specifies practices that prevent or mitigate adverse effects of 

project activities. These design features and management practices come from direction in the Forest Plan, 

and Forest Service manuals and handbooks. The design features and mitigation practices specified in the 

alternatives are outlined in Table 2-8.

Table 2- 8: Mitigation Practices and Design Features in Alternatives 2 and 3 of the Lower West Fork 

Project 

Objective Mitigation Practice or Design Feature

Soils

Minimize soil erosion and 

compaction

Activities will comply with Best Management Practices (BMPs) to minimize 

effects to soil resources. BMPs are listed in Appendix A. Complete descriptions 

are available in the Project File.

Reduce soil erosion, prevent 

sedimentation into streams, and 

prevent the spread of noxious 

weeds

Disturbed sites will be evaluated by timber sale administrators (TSAs) and/or 

resource specialists to determine erosion control and revegetation needs. Soil 

disturbances associated with landings, roadside ditches, temporary roads, or other 

areas would be rehabilitated as soon as possible by re-contouring, shallow 

ripping (6-12 inches) as needed, seeding, fertilizing, planting of shrubs, and 

covering with mulch or slash.

Minimize soil compaction Skid trails will be designated and historic skid trails will be used to the extent 

feasible in units yarded by ground-based systems.

Winter ground-based yarding is required in Unit 1 below FS road 363 

(approximately 65 acres) under Alternative 2. The winter yarding will be 

required to follow standard winter timber operating procedures. Commercial 

thinning operations will be required to limb and leave tops in this area. Woody 

debris levels should range from 15 to 20 tons/acre on the ground following 

thinning to enhance natural soil rehabilitation The woody debris will be a mix of 

fine and coarse wood.

Summer ground-based yarding will occur when soils are dry (soil moisture is 

near or below the permanent wilting point).

Winter ground-based yarding

The snow depth, distribution, and air temperature conditions must be such that 

ground-based operations maintain the following combination of snow depth and 

frozen soil conditions 

:

under

Depth of compacted (by equipment) 

snow under wheels or track/tread

the wheels or tracks/treads of equipment at all 

times. (* see below).

Minimum thickness of solidly frozen 

soil needed below compacted snow 

layer

10 or more inches 0 inches

7 to 10 inches 1 inch

4 to 7 inches 2 inches

less than 4 inches 4 inches

*Pre-trailing. Pre-trailing selected skid trails a day or so prior to skidding or 
Alternatives

Lower West Fork Project Final EIS 2-19

Objective Mitigation Practice or Design Feature

other heavy trail use is a way to achieve this objective. If average, pre-compacted 

snow depth along the proposed trail is more than 15 inches, pre-trailing can be 

done whether or not the soil is frozen. If pre-compacted snow depth is 8 to15 

inches, pre-trailing should be done only if the soil is solidly frozen in the top one 

inch or more. Otherwise, pre-trailing should be delayed until more snow falls to 

accumulate another 8 inches or more. To further aid soil protection, pre-trailing 

should be done using an “easy-does-it” approach, including slow ground speeds 

and steady movements. Avoid spinning tires and bouncing equipment on trails as 

much as possible. Adequate pre-trailing air temperatures are generally in the low 

20s  ̊Fahrenheit or lower. For more information about pre-trailing conditions, 

consult with the Forest soil scientist.

Subsoiling will occur on all skid trails used for yarding in the proposed summer 

ground-based units. If winter ground-based yarding is used in units 3 and 12,

subsoiling of historic skid trails will be required in order to create a net 

improvement in soil productivity in these units. A SGR or excavator subsoiling 

implement that achieves desired results will be used; proper application of 

subsoiling does not mix soil horizons and will cause minimal disturbance to 

surface soil/litter layers. Subsoiling will also occur on all skid trails in skyline 

units where summer, tractor swing is required. When available, slash will be 

placed on the decompacted skid trails by the SGR.

Reduce detrimental soil 

disturbance (DSD) 

Feller/buncher equipment may be used on skyline units pending the results of 

studies conducted in the Trapper Bunkhouse project area. If DSD exceeds 2%, 

then feller/bunchers will NOT be used on skyline units in the Lower West Fork 

Project area. These units will be harvested using conventional felling and skyline 

yarding methods.

Rehabilitation activities on new temporary roads and Tracked line machine trails

will include recontouring, slashing, and seeding. 

Historic roads used for hauling will be stabilized by removing drainage 

structures; ripping, seeding, and fertilizing the road bed; and closing the entrance 

to these roads. 

Reduce DSD and prevent the 

spread of noxious weeds

Hand pile sizes inside units will average 6-8 feet in diameter so localized areas of 

soil disturbance will be less than about 50 square feet. This does not pertain to 

slash created on landings during yarding operations.

Burning of piles should occur during wet conditions when the duff is moist. The 

entire duff profile should be moist to the touch in the pile locations.

Prevent the creation of new areas 

of DSD 

Where feasible, pile and burn slash where detrimental soil disturbance already 

exists, such as on old log landings, skid trails, and roads associated with the past 

harvest units. This practice will prevent the creation of new areas of detrimental 

soil disturbance.

Maintain 70% ground cover

The soil scientist will be consulted prior to burning to ensure soil conditions are 

acceptable for burning. Prescribed burning in terrace and non-terraced noncommercial thin units will only be completed through piling and burning on a 

case by case basis, pending field review by the soil scientist. 

At least 70 percent ground cover is necessary to prevent detrimental accelerated 

erosion and loss in soil productivity after treatments are completed. Ground 

cover includes duff, organic soil horizons, vegetation basal area, fine woody 

debris, coarse woody debris (CWD), and surface coarse fragments. In those 

cases where ground cover is less than 70 percent prior to burning, fuel 

consumption and ground cover loss should not exceed 15 percent. Prescribe fire 

prescriptions will be designed to meet these soil protection requirements.
Alternatives

2-20 Lower West Fork Project Final EIS 

Objective Mitigation Practice or Design Feature

Maintain soil productivity

CWD (material greater than 3 inches in diameter) left on site will include leave 

trees both standing and down, and broken limbs and tops created by timber 

harvest. Amounts will be within ranges identified in Section 1.7 D, with the 

exception of unit 1 and terraced units. 

In unit 1, fine and coarse woody debris from logging slash will be spread 

uniformly across the compacted portions of the ground-based unit (below FS 

road 363) at a rate of 15 to 20 tons/acre to increase organic matter for soil 

rehabilitation. Under burning will not be completed in this 65 acre area of unit 1. 

Mechanical thinning operations in terrace units will ensure adequate woody 

debris (fine and coarse wood) is left for soil rehabilitation on the terrace benches. 

This may require some limbing and leaving tops to ensure an adequate amount of 

woody debris is available for soil rehabilitation on the benches. An organic 

fertilizer, woody debris (rate of 10 to 15 tons/acre), or combination of both will 

be applied following subsoiling or ripping on the terrace benches to improve soil 

organic concentrations, nutrient cycling, and microbial populations. Risers in 

between benches should meet CWD standards described in Section 1.7 D. Under 

burning will not be completed on the terrace units. If fuel reduction is required 

after mechanical harvest and soil rehabilitation activities, piling and burning will 

be completed on a case by case basis pending field review by the soil scientist. 

Woody debris levels should be 10 to 15 tons/acre throughout the non-terraced 

plantations following all treatments including potential piling and burning.

The silvicultural prescriptions will be designed to account for future large CWD 

(>15 inches diameter) recruitment that will meet acceptable levels in stands 

where CWD is less than minimum levels before treatment. CWD will be left in 

these stands to the extent feasible to meet minimum requirements that do not 

pose a fuels hazard. High amounts of small CWD (3-15 inches diameter) may 

present wildfire risks.

CWD will generally be evenly distributed on each acre, unless otherwise agreed 

to by the Contracting Officer or their designee. 

Prescribed burning operations will maintain CWD levels where existing CWD is 

less than required minimum levels. Burning should attempt to increase CWD 

recruitment where possible. 

Wood larger than 15 inches in diameter will not be intentionally ignited during 

hand lighting. It is understood that once hand crews light the fire, fire may burn 

into and combust some large CWD. Coarse woody debris will meet standards 

stated in Section 1.7 D, with the exception of terrace units and unit 1.

Allow time for nutrients to leach 

from slash prior to burning

The slash will be left in all commercial thin units through one winter after cutting 

to allow for initial decomposition and nutrient leaching.

Watershed and Fisheries

Ensure that water-related 

beneficial uses are protected and 

that State water quality standards 

are met

Trees will not be harvested from Riparian Habitat Conservation Areas (RHCAs). 

If trees felled outside of the RHCAs land or roll into the RHCAs, their boles may 

be removed, but the tops and limbs will be left behind. The RHCAs are:

within 300 feet of fish-bearing streams

within 150 feet of permanently flowing, non-fish bearing streams

within 100 feet of seasonally flowing or intermittent streams

within 150 feet of ponds, lakes or wetlands > 1 acre in area

within 50 feet of ponds, lakes or wetlands < 1 acre in area

within 50 feet of landslide prone areas (USDA Forest Service 1995).

RHCA boundaries will be designated and marked on the ground in consultation 

with the Fisheries Biologist. 

Ensure that water-related In RHCAs, trees can be felled when they pose a safety risk. Felled hazard trees 
Alternatives

Lower West Fork Project Final EIS 2-21

Objective Mitigation Practice or Design Feature

beneficial uses are protected cont. will be left on-site (INFISH standard RA-2), unless their removal is deemed 

necessary for safety reasons by the TSA. 

Log landings, temporary roads, and tracked line machine trails will not be located 

in the RHCAs.

Generally, no fuel storage, mixing of fuels, or refueling equipment will occur in 

the RHCAs. If there are no other alternative areas, refueling sites in RHCAs may 

be used, but they must be approved by the Fisheries Biologist and have an 

approved spill containment plan prior to their use. Small pumps (for example, 

Mark III) and chainsaws can be refueled within the RHCA as long as proper spill 

containment actions are implemented (USDA Forest Service1995).

Protect the streamside 

management zone (SMZ) All activities will comply with the Montana Streamside Management Zone Act.

Ground-based equipment will be prohibited from entering SMZs without the 

appropriate variance from Montana DNRC. Boundaries of RHCAs will be 

marked to exclude equipment operation.

Best Management Practices will be applied and monitored during the 

administration of the contract. Applicable BMPs are in the Project File and 

summarized in Appendix A.

Protect Forest roads used during 

log hauling operations

The TSA and/or resource specialists will monitor road conditions to ensure they 

do not contribute sediment to streams. Road maintenance activities (including 

snowplowing and dust abatement) will follow the requirements specified in the 

USFSW1 Programmatic Biological Assessment for road maintenance (1999). 

Prevent sediment entering streams 

from encroached segments of haul 

roads

On the encroached haul road segments (Pierce Creek #363, Lavene Creek #5630, 

and Piquett Creek #49 Roads) –

Ø Straw bale check dams will be installed below the outlets of all ditch relief 

culverts, in the road ditches that empty into streams, and below road 

drainage features such as drive-thru dips that lack adequate riparian filter 

distance. The check dams will be installed prior to winter hauling, and 

maintained during all periods of winter hauling. 

Ø Outlets of all ditch relief pipes will be kept free of snow blockage during 

winter haul.

Ø Snow berm drainage holes will be designated prior to winter haul, and kept 

open throughout the duration of winter hauling.

Roads proposed for long-term 

storage or culvert 

removal/restoration

Seed, fertilize and slash roads after decompaction and/or recontouring, mulch to 

the extent feasible. Seed mix will be as prescribed by the Forest Botanist. Mulch 

is required on sites located within sediment contributing distance of streams 

(about 300 feet). Where culverts with flowing water are removed, a strawbale 

check dam will be installed below the outlet prior to removing the culvert. 

All units with manual thinning Trees will not be manually thinned and slash piles will not be created within 50 

feet of streams and wetlands. 

Protect RHCAs during prescribed 

burning

Helicopter ignition will not occur in the RHCAs. Hand ignition can occur in all 

of the RHCAs except wetlands. Fire will be allowed to back into or burn through 

the RHCAs. 

In Units 32, 33, and 60A, no ignition (hand or helicopter) will occur within 300 

feet of Pierce Creek and Lavene Creek.

Generally, hand fireline will not be dug in the RHCAs. If needed, hand fireline 

can be dug in the RHCAs, but it must 1) avoid wetlands, 2) be constructed with 

proper drainage structures, and 3) be recontoured and covered with slash upon 

completion of the burn. Machine fireline is prohibited in all RHCAs. 

If drafting from streams occurs, intake hoses will be fitted with a screen mesh 

equal to or smaller than 3/32 inches. Intake hoses will be placed in low velocity 

portions of the stream channel (< 0.4 feet/second of flow).

Protect aquatic resources and 

ground water during herbicide 

(W1) Mixing and loading of tanks will occur more than 300 feet from live water 

where possible. No mixing will occur within 100 feet of live water.
Alternatives

2-22 Lower West Fork Project Final EIS 

Objective Mitigation Practice or Design Feature

application

High effectiveness

Application standards.

(A1) Herbicides will not be used to control weeds within a 100-foot radius of any 

potable water spring development or diversion within the project area.

Protect aquatic resources during 

herbicide applications

High effectiveness.

Avoids potentially harmful 

exposure

(A2) No ester formulations of herbicides will be used (i.e., 2,4-D ester, triclopyrBEE), due to relatively high fish toxicity.

Protect aquatic resources and 

ground water during herbicide 

applications

High effectiveness.

Practical experience.

(A3) Use of herbicides and surfactants within 100 feet of surface water will

adhere to distances and conditions outlined in Table 3.7-4, Herbicide Use 

Restrictions in RHCAs (Chapter 3 section 3.7 Fisheries)

(A4) In areas adjacent to known stream reaches where bull trout spawn (Boulder 

Creek and Piquett Creek), no herbicides would be used within 15 feet of the 

stream, no picloram within 100 feet, and no application after July 15.

Timber Management

Prevent pine engraver (Ips spp.) 

population increases

All thinning in units with ponderosa pine and lodgepole pine must be performed 

between the months of July 1 thru December 31. Slash must be properly disposed 

of, i.e., piled and burned or lopped and scattered. Where limbs and tops exceed 

three inches in diameter, they need to be bucked in four-foot lengths and 

scattered to allow time for larger boles to dry out and not become Ips beetle host 

sites the following year. 

Prevent the spread of annosus root 

disease

Apply borate to freshly cut ponderosa pine stumps greater than 12 inches in 

diameter inside bark.

Protect TES Plant Populations and their Habitat/Promote Healthy Native Plant Communities

Avoid dwarf onion populations 

during harvest operations in units 

3, 18, 41, 64, 68, 69, 70, 73, 74

Dwarf onion (Allium parvum) populations will be located by GPS and marked on 

sale area maps for avoidance during skidding and slash piling.

Avoid Rocky Mountain paintbrush 

populations during harvest 

operations in units 6 and 70

Rocky Mountain paintbrush (Castilleja covilleana) populations will be located 

by GPS and marked on sale area maps for avoidance during skidding and slash 

piling.

Avoid Lemhi penstemon 

populations in units 22 and 66

Lemhi penstemon (Penstemon lemhiensis) populations will be located by GPS 

and marked on sale area maps for avoidance during skidding and slash piling.

To reduce the risk of weed spread 

All Units

Clean equipment prior to moving into the project area, minimize soil disturbance, 

and revegetate disturbed soil where native plant recovery may be delayed 

(consult Forest Botanist for specific recommendations) as outlined in FSM 2000, 

Zero Code 2080 – Noxious Weed Management (R1 Supplement No. 2000-2001-

1). 

Landings, Temp Roads, TLM 

paths

Botanist will evaluate temporary roads, TLM paths, and landing locations that 

have not previously been surveyed for sensitive plants. Sensitive plant locations 

would be avoided or an alternate site would be used.

Herbicide Treatments

(Alternative 2)

Lemhi penstemon plants along NFS roads 13423 and 5723 will be avoided 

during roadside spraying. The Forest Botanist will be contacted prior to off-road 

herbicide applications to ensure that sensitive plants will be avoided. Sensitive 

plants are known to occur in units 3, 18, 22, 41, 64, 66, 68, 69, 70, 73, and 74. 

GPS locations will be made available to applicators so plants can be avoided. 

Prevent weed spread along road 

corridors

Treat haul roads and access roads with herbicides prior to implementing harvest 

and/or burning activities. 

Promote successful revegetation Treat temporary roads, TLM trails and landings with herbicides after harvest 

activities are completed and prior to revegetating. 

Protect sensitive plants from 

herbicides

(SP1) Consult with district/forest botanist each year for updates to speciesspecific protection measures, before any site applications begin.

(SP2) All treatment sites will be evaluated for sensitive plant habitat suitability. 
Alternatives

Lower West Fork Project Final EIS 2-23

Objective Mitigation Practice or Design Feature

Protect sensitive plants from 

herbicides (cont.)

Moderate to High Effectiveness

Highly suitable habitat will be surveyed as necessary prior to treatment.

(SP3) Provide the weed crew with maps of all known sensitive plant locations so 

that these sites can be identified and protected.

(SP4) Train the weed crew to identify sensitive plants so that new sites can be 

identified and protected.

(SP5) The Forest Botanist will provide site-specific treatment guidelines for 

weed infestations within or adjacent to known sensitive plant populations.

(SP6) No spraying with vehicle-based spraying devices will be done within 50 

feet of any known sensitive plant occurrence.

(SP7) No chemical spraying will be done within 25 feet of any known sensitive 

plant occurrence, only mechanical treatment would be used.

Herbicide Use (Alternative 2)

Control Application Rates; 

Moderate effectiveness

Monitor –equipment for wear

(H1) Operators shall calibrate spray equipment at regular intervals 

(approximately after every 80 to 160 hours of use) to ensure proper rates of 

herbicide applications using standard methods.

Ensure responsible application of 

herbicide; Moderate effectiveness 

Monitor –Daily Pesticide 

Application Record or similar 

database.

(H2) Herbicides will be used in accordance with label instructions and 

restrictions. Application will be done or supervised by licensed applicators.

High effectiveness (Professional 

experience)

(H3) Herbicide applicators shall carry spill containment equipment, as described 

and in the Herbicide Emergency Spill Plan, and be familiar with and carry an 

Herbicide Emergency Spill Plan. A spill cleanup kit will be available at 

temporary storage sites and with all transportations (vehicles, raft, plane, mules) 

carrying herbicides.

Prevent spillage in rafts that may 

come into contact with humans or 

may directly enter surface waters.

High Effectiveness, Practical 

experience.

(H4) Equipment used for transportation, storage, or application of herbicides 

shall be maintained in leak proof condition. 

Prevent contact with open water. 

High effectiveness. Logic.

(H5) Chemicals will not be used over live water (streams, ponds, springs, etc.), 

including water standing or running in ditch lines.

Dry roadside ditches that lead to intermittent and perennial streams will not be 

sprayed with any herbicide containing picloram.

Avoid impact to sensitive plants 

and non-target aquatic species.

High effectiveness Professional 

experience.

(H6) Procedures for mixing, loading, and disposal of herbicides and a spill plan 

will be followed. All herbicide storage, mixing, and post-application equipment 

cleaning will be completed outside of RHCAs. If no other alternative is 

available, mixing and loading operations must take place in an area where an 

accidental spill would not contaminate a stream or body of water before it could 

be contained. Particular attention will be given to avoiding mixing, loading, or 

cleaning within 100 feet of live water. These procedures are referenced in 

Appendix A and B of the Draft Selway-Bitterroot Invasives EIS (2008). Drafting 

equipment used for filling herbicide spray tanks will be equipped with 

appropriate back-siphoning prevention devices.

Assure product safety.

High effectiveness.

EPA Studies.

(H8) Additional herbicides may be considered for use within the project area in 

the future. Only EPA registered herbicides having a completed Human Health 

and Ecological Risk Assessment Final Report will be considered for use. 

Additional consultation regarding ESA-listed species will occur for the use of 

any new herbicide not included in this Record of Decision.

Inform public and reduce 

exposure; High effectiveness 

(Logical – prevent exposure)

(H9) Roads receiving treatment will be posted with the date of treatment and 

chemical applied. 
Alternatives

2-24 Lower West Fork Project Final EIS 

Objective Mitigation Practice or Design Feature

Provide for annual, pre-application 

oversight.

High effectiveness.

Coordination.

(H10) The Annual Plan of Operations for herbicide application will be reviewed 

by an interdisciplinary team that includes, at a minimum, hydrology and or 

fisheries biology, botany, and wildlife biology skills. The review will take place 

prior to implementation to ensure the protection of native flora and fauna and to 

ensure that herbicide thresholds, as described in the Fisheries section of Chapter 

3, are not exceeded

Prevent contact with open water. 

High effectiveness. Logic.

(H11) No herbicide spraying will occur during rain or when rain is imminent.

Dry roadside ditches that lead to intermittent and perennial streams will not be 

sprayed with any herbicide containing picloram.

Protect Aquatic Resources; High 

effectiveness

Prior testing.

(H12) Use of surfactants will occur as previously described, using only the 

surfactants listed and according to the allowable distances to live water displayed 

in Table 2-9 below.

Safe handling of herbicide; High 

effectiveness (Logical – visible)

(H13) Water-soluble colorants, such as Hi-Light® blue dye, will be used within 

100 feet of water and in other situations as needed to enable applicators and 

inspectors to better see where herbicides have been applied.

General Safety; High 

Effectiveness; Logical – high 

visibility

Traffic control and signing during weed-treatment operations will be used as 

necessary to ensure safety of the public and workers.

Protect Cultural Resource sites; 

High effectiveness (Logical –

avoids impact to area)

(C1) Mechanical/cultural treatments that disturb soil, will not be used on any 

known historical or archaeological site without proper clearances by a Forest 

Heritage Resource Specialist.

Wildlife

Retain old growth habitat 

characteristics in units that contain 

old growth habitat (units 4, 8, 9, 

15, 33, 60A, 61A, 70, 71)

The Silviculturist and Wildlife Biologist will monitor stand marking and timber 

harvest to ensure the stands meet Green et al. (1995, addednum 2005) old growth 

criteria. 

Snags Retain all snags unless designated “danger” trees (29CFR 1910.266(h)(1)(vi,vii).

Retain downed, woody debris

Fire Type Group Coarse Woody Debris

 2, 4 5-10 tons/acre

 6 10-20 tons/acre

 7, 8, 9 8-24 tons/acre

Protect amphibians and herptiles

High effectiveness with training 

and diligence of applicator.

Avoids potentially harmful 

exposure.

(W1) When ground application of authorized herbicides is necessary within 50 

feet of a water body, wetland, or river beach, applicators will survey the 

treatment area at time of application to determine potential presence of 

amphibians and aquatic associated herptiles.

The broadcast spray application method will not be used if adult amphibians or 

aquatic associated herptiles are identified.

The extent of species population distribution in the treatment area will be 

reported to the district amphibian specialist (Fisheries or Wildlife Biologist) as 

soon as possible. Hand pulling or wick application will be used or treatment will 

be deferred on advice of the amphibian specialist if treatment is not possible 

without directly spraying individuals.

If tadpoles or amphibian metamorphs are identified, the location will be reported 

to the amphibian specialist and weed coordinator as soon as possible, and 

application of herbicides will be delayed until metamorphs disperse.

Reduce potential for incidental 

contact of spray compounds with 

non-target species of concern.

Moderate effectiveness due to 

tendency for some species to hide 

under rocks and debris.

Practical experience.

(W2) Avoid directly spraying any terrestrial organism other than invasive plant 

species, including snakes, lizards, salamanders, small mammals, ground nesting 

birds, and insect concentrations such as ladybug swarms.

If treatment is not possible without directly spraying individuals, then hand 

pulling or wick application will be employed.
Alternatives

Lower West Fork Project Final EIS 2-25

Objective Mitigation Practice or Design Feature

Minimize impact to nesting 

eagles; High effectiveness (MT 

Bald Eagle Working Group. 1994. 

page 24)

(W3) Activities associated with weed control will avoid areas within 400 meters 

of active bald eagle or peregrine falcon nest sites unless the Wildlife Biologist 

provides further direction.

Minimize human effects on 

wildlife.

High effectiveness.

Practical experience.

(W4) Food, garbage, and human waste associated with project implementation 

work crews will be properly managed so as not to attract or habituate wildlife.

Crew camps will be located to avoid disturbance to wildlife in reproductive sites 

during active reproductive periods, including calving and lambing areas, raptor 

nesting and carnivore den sites.

Protect Bog Lemmings.

Avoids potentially harmful

exposure.

High Effectiveness based on 

research

W5) Chemical application is prohibited within 300 feet of all sites where 

northern bog lemmings are known to occur, as well as peatland sites not yet 

surveyed for northern bog lemmings, pending review and approval by the Forest 

Wildlife Biologist.

Table 2- 9: Adjuvants (Surfactants) Proposed for Use and Allowable Distance to Live Water

2.3.1 MONITORING

Forest Service scientists will establish plots along transects in unit 70 to determine the effects of treating 

old-growth. Plots would be established using T1 Old Growth Monitoring Inventory Protocols and data 

would be collected before and after treatment. A control plot would be established to measure the effects 

of no treatment.

Forest Service fisheries biologists will conduct a mark-recapture fish population estimate in four streams 

the year after all of the timber harvest and log hauling activities have been completed in their respective 

drainages. The reaches to be monitored are: (1) Pierce Creek 0.5; (2) Lavene Creek 0.2; (3) Piquett Creek 

1.3; and (4) East Piquett Creek 0.2. Fish populations, pre-harvest and post-harvest and hauling, will be 

compared to assess consistency with predictions made in the effects analysis.

Forest Service fisheries biologists will monitor water temperatures in four streams for one summer period 

(July 18 to October 1) after all of the timber harvest, prescribed burning, and log hauling activities have 

been completed in their respective drainages. The sites to be monitored are: (1) Pierce Creek 0.4; (2) 

Lavene Creek 0.1; (3) Piquett Creek 1.3; and (4) East Piquett Creek 0.3. Post-activity water temperatures 

will be compared to pre-activity temperatures to assess consistency with predictions made in the effects 

analysis. 

Forest Service fisheries biologists will monitor the implementation and effectiveness of the fisheries 

mitigation measures during and after project implementation. Findings will be documented in unit logs and 

the annual Forest Plan Monitoring Reports. 

Units will be monitored for weed spread following harvest and prescribed fire treatments. Herbicide 

treatments may be necessary if weeds encroach into new areas. The potential for weed encroachment is

Surfactant

Distance to Live Water Use Allowed

0 – 15’ >15 – 50’ >50 –

100’ > 100’

Agri-Dex, and Super Spread MSO Yes Yes Yes Yes

Cide Kick II No Yes Yes Yes

R-11, Activator 90, X-77, Latron AG-98, Pro-Spreader Activator, 

Cide-Kick, LI-700, Spreader 90, Syl-tac, Cygnet Plus, Sylgard 

309, Freeway, Silwet L-77, Kinectic, and Inlet

No No Yes Yes

R-900, R-56, Cohere, Dyne-Amic, Bond, Tacktic, and Latron Ag98 (N) No No No Yes
Alternatives

2-26 Lower West Fork Project Final EIS 

higher on dry, open sites that are yarded using ground-based equipment and are adjacent to currently 

infested areas. Environmental effects of herbicide treatments are analyzed in Chapter 3 for Alternative 2 of 

this project. 

2.4 COMPARISON OF EFFECTS BETWEEN ALTERNATIVES 

Table 2-10 displays a summary of the effects analysis detailed in Chapter 3 relative to the issues raised in 

scoping and summarized in Table 2-1. Since the unit treatments are the same between Alternatives 2 and 3, 

the effects within the units would be the same. The differences between alternatives are of scale or spatial 

setting. 

Table 2- 10: Comparison of Alternative Effects by Issues

Issue Alternative 1 Alternative 2 Alternative 3

Soil Productivity

Soil Productivity

No change to current 

erosion and mass wasting 

regimes

No change to organic 

matter and woody debris;

No change in nutrient 

cycling.

Soil Disturbance:

Zero acres of cumulative 

detrimental soil 

disturbance greater than 

15% of an activity area.

~~~~~~

1

If future fires are within the 

historic range of variability, 

long-term effects of erosion and 

mass movement are likely to be 

relatively small. Fire intensity

exceeding the historic range of 

variability could have 

detrimental effects on erosion 

and mass movement through the 

alteration of soil hydrology and 

loss of soil organic matter and 

tree roots.

Soil Productivity

Risk that forest thinning 

and burning would initiate a 

landslide is low.

Ground cover reduced on 

an estimated 5-10% on 

ground based and skyline 

units. Groundcover 

recovery would be achieved 

with needle cast and 

vegetation re-growth.

Sufficient coarse woody 

debris left for soil 

productivity.

Nutrient cycling and 

availability unaltered at 

stand scale. Localized 

nutrient losses may occur in 

places with severe fire i.e. 

under burn piles and at 

landings.

Soil Disturbance

Cumulative detrimental soil 

disturbance (DSD) should 

not exceed 15% of area 

treatment area. In 

treatment areas that 

currently exceed 15% DSD, 

rehabilitation efforts will be 

completed to trend soil 

conditions toward a net 

improvement in 

productivity.

227 acres of soil 

potentially disturbed by 

ground-based and skyline 

yarding, and associated

activities

297 acres of terrace 

rehabilitation and 32 acres 

of decompacted historic 

Soil Productivity

Same Effects as 

Alternative 2

Soil Disturbance

Soil disturbance standards 

same as Alternative 2.

163 acres of soil 

potentially disturbed by 

ground-based and skyline 

yarding and associated 

activities

297 acres of terrace 

rehabilitation and 32 acres 

of decompacted historic 

skid trails
Alternatives

Lower West Fork Project Final EIS 2-27

Issue Alternative 1 Alternative 2 Alternative 3

skid trails.

Watershed

Sediment: 

No change to current road 

sedimentation input

Water Yield: 

No change - Present stand 

density and moisture stress 

retained.

Channel Condition: 

No change

Road/Stream Interaction: 

No change

~~~~~~

The current risk of watershed 

damage from high-intensity 

wildfire may gradually increase 

over time.

Sediment: 

Short term – Not measurable. 

Mitigation limits project-the 

quantity of generated sediment 

inputs are too small to measure.

Long term – Road sediment 

inputs reduced by 27 tons per 

year. 16 sediment-contributing 

road crossings restored to 

natural conditions

Water Yield: 

Negligible increase in 

streamflow and better soil 

moisture conditions where 

thinning or prescribed burning 

occurs.

Channel Condition: 

Short term – No changes due to 

the presence of roadside 

vegetation filters and project 

mitigation. No change to 

existing channel conditions 

through the end of log hauling.

Long term – Depending on the 

stream, ranges from no change 

to improvement due to reduced 

road sediment inputs. 

Road/Stream Interaction: 

Short term – Immeasurable 

effects from log haul on 

sediment production –

mitigation effectively reduces 

project road effects.

Long term – Road sediment 

inputs reduced by 27 tons per 

year. 16 sediment-contributing 

road crossings restored to 

natural conditions. 

Sediment: 

Short term – Same effects as 

Alternative 2 on the west side 

of the river, lower potential for 

sediment inputs on the east side 

of the river

Long term – Road sediment 

inputs reduced by 39 tons per 

year. 23 sediment-contributing 

road crossings restored to 

natural conditions

Water Yield: 

Same effects as Alternative 2

Channel Condition: 

Short term – Same effects as 

Alternative 2

Road/Stream Interaction: 

Short term – Same effects as 

Alternative 2 on the west side 

of the river, less potential for 

log haul-generated sediment 

inputs on the east side of the 

river

Long term – Road sediment 

inputs reduced by 39 tons per 

year. 23 sediment-contributing 

road crossings restored to 

natural conditions

Fisheries

Sediment:

No net benefit or impact

Water Temp:

No effect on shade and 

therefore temperature.

Large Wood: 

No net benefit or impact 

Aquatic Connectivity: 

No benefit or impact.

Sediment:

Short term – Not 

measurable. Mitigation 

limits project-quantities of 

generated sediment are too 

small to be measured.

Long term – Road 

sediments inputs reduced 

by 27 tons per year. 16 

Sediment: 

Short term – Same effects 

as Alternative 2 on the 

west side of the river, 

lower potential for 

sediment inputs on the east 

side of the river.

Long term – Road 

sediments inputs reduced 
Alternatives

2-28 Lower West Fork Project Final EIS 

Issue Alternative 1 Alternative 2 Alternative 3

sediment-contributing road 

crossings restored to 

natural conditions

Water Temp & Large 

Wood:

Maintained. No 

measurable changes in 

temperatures or woody 

debris recruitment as a 

result of the protection 

afforded by RHCAs

Aquatic Connectivity: 

Improved. Seven fish 

barrier culverts eliminated 

(5 replacements + 2 

removals)

by 39 tons per year. 23 

sediment-contributing road 

crossings restored to 

natural conditions

Water Temp & Large 

Wood:

Same effects as Alternative 

2

Aquatic Connectivity: 

Same effects as Alternative 

2

Wildlife

Old growth 

habitat

No old growth stands 

treated.

No effect to existing old 

growth habitat 

percentages or conditions.

Slower progression of 

immature stands toward 

old growth than in thinned 

stands.

 ~~~~~~

o Increasing risk of losing

old growth habitat. 

Increasing tree densities 

and fuel loads would 

increase the probability of 

large, stand replacement 

fires. 

260 acres of old growth 

treated: 205 acres with 

prescribed fire and 55acres 

with commercial thin and 

prescribed fire.

No reduction in the amount 

of existing old growth or 

old growth habitat 

conditions. 

Helps move treated stands 

towards old growth 

conditions in the long term 

by reducing high stocking 

densities that result in slow

stand growth.

~~~~~~

Reduces the risk of losing 

existing old growth 

habitat to severe fire or 

insect outbreaks by 

reducing stand density and 

ladder fuels.

228 acres of old growth 

treated: 202 acres with 

prescribed fire and 26

acres with commercial 

thin and prescribed fire.

Similar effects as in 

Alternative 2 though no 

fuel reduction treatments 

would occur on the east 

side of the West Fork 

River.

Old growth

“associate” 

species.

No change to existing 

habitat quality for marten, 

fisher, pileated 

woodpecker, or 

flammulated owl.

Short-term habitat quality 

will likely continue to 

improve for marten, 

pileated woodpecker, and 

fisher habitats as tree 

densities increase.

Short-term habitat quality 

will likely continue to 

Marten and Fisher - Treats 

about 3,200 acres of 

potential (720 acres) and 

suitable habitat (2500 

acres). Treats 18% of 

suitable habitat.

Pileated Woodpecker -

Treats about 3,700 acres of 

potential (700 acres) and 

suitable (3,000 acres)

habitat. Treats 32 to 34%

suitable habitat. 

Flammulated Owl - Treats 

Marten and Fisher - Treats 

about 2,400 acres of 

potential (450 acres) and 

suitable (1950 acres) 14% 

of suitable habitat treated. 

Pileated Woodpecker -

Treats about 2,370 acres of 

potential (370 acres) and 

suitable (2,000 acres)

Flammulated Owl - Treats 

about 2,245 acres of 

potential (435 acres) and 

suitable (1,810 acres). 
Alternatives

Lower West Fork Project Final EIS 2-29

Issue Alternative 1 Alternative 2 Alternative 3

decline for flammulated 

owl habitats as tree 

densities increase.

~~~~~~

A large fire could create 

unsuitable habitat for 

marten, pileated 

woodpeckers, flammulated 

owls, and marten in areas 

that burned with moderate 

or high intensities. 

about 3,460 acres of 

potential (690 acres) and 

suitable (2,770 acres)

Treats 27% of suitable 

habitat. 

Some loss of potential 

fisher habitat would occur.

No change in the amount 

of flammulated owl 

habitat; improvement in 

habitat structure.

Excess habitat to maintain 

viable populations exists 

Forest and area wide, for 

marten, pileated 

woodpecker, flammulated 

owl, and fisher habitat so 

the project would not 

likely influence population 

or species viability.

~~~~~~

Reduces the risk of losing 

existing marten, pileated 

woodpecker, flammulated 

owl, and fisher habitat to 

severe fire or insect 

outbreaks by reducing 

stocking densities and fuel 

loadings on 5,053 acres.

Treats 18% of suitable 

habitat.

Similar Effects as 

Alternative 2 

~~~~~~

Reduces the risk of losing 

existing marten, pileated 

woodpecker, flammulated owl, 

and fisher habitat to severe fire 

or insect outbreaks by reducing 

stocking densities and fuel 

loadings on 3,388 acres

Elk habitat 20% of winter range is 

thermal cover; 21% of 

MA-2 is thermal cover.

~~~~~~

Road density greater than 

2.0 mi/mi2 in 6-3rd order 

drainages.

~~~~~~

53% of analysis area 

provides security habitat

17% of winter range is 

thermal cover; 17% of

MA-2 is thermal cover.

~~~~~~

Road density greater than 

2.0 mi/mi2 in 5-3rd order 

drainages.

~~~~~~

53% of analysis area 

provides security habitat

19% of winter range is 

thermal cover; 20% of 

MA-2 is thermal cover.

~~~~~~

Road density greater than 

2.0 mi/mi2 in 5-3rd order 

drainages.

~~~~~~

53% of analysis area 

provides security habitat

Recreation and Roadless

No impact to recreation 

opportunities.

No change to inventoried 

roadless areas or unroaded 

areas.

No impact to recreation 

opportunities.

No change to inventoried 

roadless areas or unroaded 

areas.

Could increase crosscountry travel.

Minor temporary effects 

on individuals in or near 

the area could occur 

during treatment activities 

including road closures, 

Similar Effects as 

Alternative 2 
Alternatives

2-30 Lower West Fork Project Final EIS 

Issue Alternative 1 Alternative 2 Alternative 3

increased traffic, smoke,

and noise.

Visuals

Forest Plan visual quality 

objectives would be met

Forest Plan visual quality 

objectives would be met

project design and 

mitigations.

Visual impact of several 

old clear cuts reduced by 

feathering edges.

Same Effects as 

Alternative 2

Noxious Weeds

No direct change to 

individual plants or spread 

of weeds. 

Current trend of noxious 

weed spread continues at 

a low to moderate rate. 

~~~~~~

High intensity fire more 

conducive to spotted 

knapweed spread.

Potential for weed spread 

minimized through 

preventive mitigation, 

monitoring, and herbicide 

treatments.

29 miles of roads closed 

after herbicide treatments 

(reduces potential weedspread in corridors).

Potential for weed spread 

minimized through 

mitigation. Weed spread 

continues at a low to 

moderate rate. 

46 miles of roads are 

closed. This reduces the 

number of corridors for 

weed spread, but without 

herbicide treatment would 

not be as effective as 

Alternative 2.

Economic Assessment

No effect

Present value Revenue

 $172,650

Revenue for Stewardship

 139,981

discounted revenue 

including required 

mitigation

 PNV = $-933,864 

Total harvest and all other 

activities

PNV= $-1,966,013

Total Part- and Full-time 

Jobs: 170

Present value Revenue

 $123,801

Revenue for Stewardship

 100,375

discounted revenue 

including required 

mitigation: 

 PNV = $-726,549 

Total harvest and all other 

activities

PNV= $-1,646,559

Total Part- and Full-time 

Jobs: 121 1 The open circle (o) indicates mid- to long-term cumulative effects with wildfire.




Affected Environment and Environmental Consequences - Introduction

Lower West Fork Project Final EIS 3.1-1

CHAPTER 3.0

AFFECTED ENVIRONMENT AND 

ENVIRONMENTAL CONSEQUENCES

3.1 INTRODUCTION

This chapter summarizes the affected physical, biological, social, and economic environments of the

analysis area and the effects of implementing each alternative on those environments. It also presents the 

scientific and analytical basis for the comparison of alternatives presented in the tables in Section 2.7 of

Chapter 2.

Each of the resource analyses in this chapter includes an Affected Environment section that describes the 

geographic and temporal scope of the current resource conditions. We use these boundaries to define the 

extent and magnitude of effects in the subsequent environmental consequences analysis. The effects area 

for a particular resource is related to the scientific parameters of the resource and may not be confined to

the boundaries of the analysis area. For example, the effects area for air quality analysis comprises much 

of Ravalli County. 

The resource information provided in the Affected Environment narratives includes the effects of past 

actions that are now part of the existing condition. For example, several treatments have occurred in Unit 1 

since 1968. In the 239-acre unit, 159 acres have had partial harvests, five acres have been clearcut, and 3 

acres were pre-commercial thinned. Another 37 acres that received an improvement cut in 1968 were precommercially thinned in 1976. Also during this time, almost 2 miles of road were constructed to access 

these units. Several resource-specific assessments of the affected environment would account for the 

effects of harvest and road construction that occurred in the past 30 years. The following illustrates how

we consider past actions in the affected environment:

Ø The existing successional stage distribution described in the vegetation section reflects the change 

in forest structure from past harvest. Field examinations identify stand composition, stocking, 

structure class, cover type, and other stand and forest criteria used to describe existing vegetation 

and wildlife habitat conditions.

Ø The existing level of past regeneration harvest in the project area includes the five acres of clearcut 

harvest.

Ø Stream channel surveys assessing stream conditions in the project area would reflect any remaining 

physical and biological effects of the past timber sale and road construction. These field 

classifications of existing conditions of specific streams are disclosed in the fisheries and 

hydrology sections Affected Environment sections of this chapter.

Ø The existing watershed conditions account for the contribution of sediment and increased stream 

flow from the two miles of road construction when the road segments and their construction dates 

are entered into the WEPP model. Likewise, the existing condition model outputs, based on 

vegetation and validated through field and aerial photo analysis, reflect any residual effects of the 

159-acre harvest unit.

Ø Field examinations of road conditions provide additional data on residual contributions of sediment 

from the two miles of road. These effects are incorporated into existing road condition disclosures 

and provide a basis for proposed BMP projects to improved drainage, if needed as mitigation for 

newly proposed actions.
Affected Environment and Environmental Consequences - Introduction

3.1- 2 Lower West Fork Project Final EIS 

Ø Soil field exams classify soil disturbance from yarding logs during previous harvests. This 

information is disclosed in the Affected Environment section of the Soils analysis and provides the 

basis for logging system recommendations in the current harvest proposal. 

Ø Specific past actions considered in the Affected Environment analysis are listed in Appendix B. 

The list of past actions is not necessarily exhaustive, as records may not exist for all past activities 

(by project). This is particularly true for those actions that predate the passage of NEPA in 1970. 

Nevertheless, the assessment of existing condition reflects the effects of past actions to the extent 

they continue to affect particular resources.

3.1.1 ENVIRONMENTAL CONSEQUENCES ANALYSIS

The Environmental Consequences sections discuss in detail the environmental effects that would occur for 

each alternative. It forms the scientific and analytical basis for the alternative comparisons presented at the 

end of Chapter 2 and in the summary (40 CFR 1502.16). The effects of the No-Action alternative,

Alternative 1, form a baseline against which the other alternatives are evaluated. Each narrative begins 

with a brief explanation of how issues and effects were analyzed and the models used. The measures of 

success, described in Section 1.4 of Chapter 1, are used to evaluate how each alternative meets the purpose 

and need is assessed using the. 

Both action alternatives include slightly different vegetation and fuel management treatments; therefore, the 

environmental effects of the alternatives vary slightly. The level of detail for each resource analysis 

depends on the character of that resource, the amount of information available, importance of effects, and 

the scale of analysis most informative or relevant for that affected resource.

Environmental effects can be direct, indirect, or cumulative. They can be of long or short duration. Effects 

can be quantitative or qualitative, adverse or beneficial, actual or potential. It is important to consider 

timing and location of effects. Direct effects are caused by the action and occur at the same time and place. 

Indirect effects are caused by the action and are later in time or further removed in distance, but are still

reasonably foreseeable (40 CFR 1508.8). In most cases, direct and indirect effects are discussed together. 

Cumulative effects are those that result from the incremental impact of the action when added to other past, 

present, and reasonable foreseeable actions (40 CFR 1508.7). Therefore, the discussion of effects first 

considers the direct and indirect effects of each alternative. Appendix B describes other actions (past, other 

present, reasonably foreseeable) that have the potential to contribute to cumulative effects for the resources 

in the area. Each resource area considers the relevant past, present, and reasonably foreseeable actions as 

they affect their resource.

The cumulative effects analysis builds on the existing condition assessment in the affected environment by 

considering the incremental addition of direct and indirect effects of proposed as well as present and 

reasonably foreseeable actions. While impacts can be differentiated by direct, indirect, and cumulative, the 

concept of cumulative impacts takes into account the compounding effects of disturbances resulting from 

all actions.

Discussions under each resource include a description of the regulatory framework specific to the resource. 

Environmental laws provide the Forest Service direction for management of forest resources. The Code of 

Federal Regulations (CFRs), Administrative Rules of Montana (ARMs), Bitterroot National Forest Plan

(Forest Plan), and Forest Service Manual interpret and define these laws. The regulatory framework 

associated with each resource relates national Forest Service and Bitterroot National Forest direction on

resource analysis procedures. The regulatory framework is included in the Affected Environment section, 

with regulatory consistency findings at the end of the effects analysis for each alternative.
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-1

3.2 VEGETATION (SILVICULTURE)

3.2.1 SCOPE OF ANALYSIS AND ANALYSIS METHODS

A. Analysis Area

The analysis area is in the Bitterroot Valley Section M332B (McNab and Avers 1994) of the Middle Rocky 

Mountain Steppe-Coniferous Forest-Alpine Meadow Province M332 of the Temperate Steppe Division 

M330 of the Dry Domain 300 (Bailey 1994). Elevations in the project area range from 5,000 to 6,800 feet. 

The Bitterroot Mountains are glaciated mountains with alpine ridges and cirques at the higher elevations,

and glacial or lacustrine basins at lower elevations. Steep slopes, sharp crests, and narrow valleys 

characterize these mountains. Elevations range between 2,500 and 6,000 ft (763 to 1,830 m) in basin areas,

and 3,000 to 8,000 ft (915 to 2,440 m) at the mountain ridges and peaks. Elevations of some alpine areas 

extend to 10,000 ft (3,050 m) (McNab and Avers 1994). 

Pacific Ocean and arctic continental air masses modify climate in the project area. This produces mild 

winters and relatively dry summers. Precipitation ranges from 12 inches at lower elevations to over 80 

inches in the mountains, with 60 percent of it falling as snow. Most precipitation occurs between October 

and May (Bitterroot National Forest (Bitterroot NF) 1999). 

The analysis area consists of approximately 38,375 acres of National Forest System land. The private land 

located within the project area was not included in the vegetation analysis. The analysis area is located 

between the Selway Bitterroot Wilderness to the west, the Sula district boundary to the east and the Darby 

District boundary, Trapper Creek drainage to the north. The south edge of the project area extends to 

Rombo Mountain and connects back to the West Fork Ranger Station. 

Coniferous forest is the dominant vegetation cover in the Lower West Fork project area. Grasslands occur 

on some south facing slopes and upland ridges. The riparian areas are predominantly shrubs with small 

amounts of aspen. On south-facing, lower elevation slopes, ponderosa pine (Pinus ponderosa (var. 

ponderosa)) is the dominant tree species, usually growing with Douglas-fir (Pseudotsuga menziesii (var.

glauca)) on other aspects. The elevation range of ponderosa pine in the project area is between 4,400 and

6,000 feet. Lower elevation north to northeast facing slopes also consist of ponderosa pine/Douglas-fir mix 

and include spruce (Picea engelmannii) and minor amounts of lodgepole pine (Pinus contorta (var. 

latifolia)). Around 6,000 feet in elevation, subalpine fir (Abies lasiocarpa) replaces ponderosa pine in the 

tree species mix. Lodgepole pine, found in minor amounts at lower elevations, is more abundant at higher 

elevations, mixed with Douglas-fir and subalpine fir or in almost pure stands. A minor amount of white 

bark pine (Pinus albicaulis) may be found at elevations above 7,500 – 8,000 feet. 

B. Stand Diagnosis

Description

A stand diagnosis is the preliminary documentation of current stand and site conditions. The stand 

diagnosis includes information such as slope, aspect, elevation, land type, habitat type, vegetation 

characteristics, access options, and potential logging constraints. Desired vegetation conditions and

treatment options are recorded, and a preferred treatment selected. Diagnoses were made for individual 

stands, as well as, proposed treatment units, which may be composed of several stands. Detailed stand

exams or walk through exams were started in the summer of 2007 for all units designated for commercial 

treatment and were completed in the summer of 2008. Information used in the diagnosis was gathered 

from various sources and in a variety of ways including aerial photographs, ‘walk-throughs’, stand exams,

and data from past stand exams (Timber Stand Management Record System (TSMRS) database). 

Primary Use in Analysis

Primary use in this analysis was for developing the proposed action and other action alternatives, as well as 

developing preliminary treatment options and prescriptions. 
Affected Environment & Environmental Consequences – Silviculture

3.2-2 Lower West Fork Project Final EIS 

Core Assumptions and Limitations 

One limitation of this data is that during the initial walk-through or stand exam, not every piece of ground 

or every piece of each stand is covered. Conditions could exist that the data does not represent. However, 

by using aerial photographs, TSMRS data, and their own field knowledge, Bitterroot NF Silviculturists 

would know of most unique conditions and account for them in the diagnosis. 

Anticipated Consequences of Limitations

Diagnosis is one step in the process that leads to the silviculture prescription for proposed treatments. Data 

collected during the diagnosis phase is preliminary and iterative. As more in depth field work occurs 

diagnosis information would be updated and refined in preparation for treatment prescriptions. 

Description

Timber Stand Management Record System (TSMRS)

Stand data is maintained in the TSMRS database and provides the information managers need to manage 

the timber resource (USDA Forest Service 1996e). This record system stores the historical record of all 

stand treatments, and provides information for silviculture prescriptions, treatment plans, and schedules;

required reports; and updating and amending Forest Plans. The data is collected in a variety of ways,

including field surveys and aerial photo interpretation. The usefulness of the system is directly 

proportional to the reliability and completeness of the data entered. Timber resource managers regularly 

update the data. 

Primary Use in Analysis

TSMRS data was used to understand past harvest and post sale treatments such as, site preparation, 

planting and timber stand improvement (thinning), habitat types, forest cover types, and forest structural 

stages. This data provides the record of activities that have occurred in the project area and are filed in the 

project file (PF-SILV-001-021). 

Core Assumptions and Limitations

There are three components to TSMRS; an Index Map; a Stand Folder; and an Automated Data Base. All 

three components function together; the index map is the primary index for all stands in the system, the 

stand folder contains all the detail needed for management; and the database allows the compiling and 

summarizing of information. 

The stand is the basic unit for record keeping. While stand size and shape may change, every stand number 

is unique. A new stand can be delineated where none was previously recognized or defined as a smaller 

part of an existing stand or stands. In this analysis, similar stands with similar habitat types were combined 

into vegetation response units (VRUs) for treatment prescriptions. 

Some data was gathered using formal stand exam protocols, which have a corresponding statistical 

analysis. Compartment exams, done by aerial photo interpretation and walk-through exams are other ways 

data are collected, though they are not statistically accurate. These types of data collection depend on 

individual interpretations and their expertise. 

Anticipated Consequences of Limitations

TSMRS is not a spatial database; meaning that treatments occurring in a portion of the stand are not 

delineated in the stand but are shown as occurring over the whole stand. Showing treatments on a map then 

displays the entire stand instead of that portion treated. While the correct area of the treatment can be 

tabulated, the spatial location of that treatment cannot be displayed. The maps (PF-SILV-017-018-019) 

showing past harvest or other activities should be reviewed with the associated area of treatment in the 

same Appendix as neither of these are stand alone documents. 

TSMRS was implemented in the late 1980s. Historical activity data prior to the late 1980s may not be as 

complete and accurate as the later data. Currently, the TSMRS database has been replaced by the Forest 

Activity Tracking System (FACTS). However, since very little recent or ongoing activities have occurred 
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-3

in the project area, TSMRS data is relevant for use in this project. TSMRS data gaps were considered and 

filled using aerial photo interpretation and verified with walk-through exams. Most of the data gaps were 

outside the treatment areas and are relevant to the analysis at the landscape level but were not important for 

predicting site-specific treatment effects.

We did not rely exclusively on TSMRS data in the development and analysis of the Lower West Fork

project. Ongoing field visits since 2006 by Interdisciplinary Team (ID Team) members provide firsthand

knowledge of the project area, and TSMRS data is used in a supporting role. 

3.2.2. REGULATORY FRAMEWORK

A. National Forest Management Act 

The minimum specific management requirements for projects or activities that must be met in carrying out 

projects and activities for the National Forest System (NFS) are set forth in this section. Under 16 U.S.C. 

1604 (g) (3) (E), a Responsible Official may authorize site-specific projects and activities to harvest timber 

on NFS lands only where:

1921.12a-Timber Management Requirements

1. Soil, slope, or other watershed conditions will not be irreversibly damaged. Response:

Refer to the soils and watershed sections.

2. There is assurance that the lands can be adequately restocked within five years after 

final regeneration harvest (FSM 1921.12g). Response: Stands within the project area that 

have had regeneration harvests from the 1950s to the present have been certified. In this 

project, we do not propose stand regeneration harvest. Stands would remain fully stocked 

following commercial thinning treatments. 

3. Streams, streambanks, shorelines, lakes, wetlands, and other bodies of water are 

protected from detrimental changes in water temperatures, blockages of watercourses, and 

deposits of sediment where harvests are likely to seriously and adversely affect water 

conditions or fish habitat. Response: Refer to the soils and watershed sections.

4. The harvesting system to be used is not selected primarily because it will give the 

greatest dollar return or the greatest unit output of timber. Response: The harvesting 

systems used in Lower West Fork were selected based on site-specific resource needs and 

not selected primarily to give the greatest dollar return or the greatest output of timber.

A Responsible Official may authorize projects and activities on NFS lands using cutting methods, such as 

clearcutting, seed tree cutting, shelterwood cutting, and other cuts designed to regenerate an even-aged 

stand of timber, only where: 

1. For clearcutting, it is the optimum method; or where seed tree, shelterwood, and other cuts are 

determined to be appropriate to meeting the objectives and requirements of the relevant plan (16 

U.S.C. 1604 (g)(3)(F)(i)). Response: Large patches of saw-timber size, older (generally greater 

than 110 years-old) lodgepole pine exists in some units; these patches will be cut and removed 

creating openings within the thinning units. These openings will range in size from less than onequarter acre up to 10 acres. Other species growing in these lodgepole pine areas will be retained if 

they are healthy and windfirm. Dwarf-mistletoe infests the lodgepole pine, which are showing

signs of mountain pine beetle-caused mortality and increasing levels of mountain pine beetle 

activity. Thinning these areas is not recommended since the residual trees are likely not healthy 

enough to survive after the stand is opened up. Cutting these patches meets the purpose and need 

of this project and Forest Plan goals. Also, patch cuts less than 5 acres in size will be prescribed

where Douglas-fir is heavily infested with dwarf mistletoe. Five-acre patch cuts in Douglas-fir 
Affected Environment & Environmental Consequences – Silviculture

3.2-4 Lower West Fork Project Final EIS 

would be the outside size limit and not the norm. Most openings would average one-quarter to two 

acres in size.

2. The interdisciplinary review has been completed and the potential environmental, biological, 

aesthetic, engineering, and economic impacts have been assessed on each advertised sale area and 

the cutting methods are consistent with the multiple use of the general area (16 U.S.C. 1604 

(g)(3)(F)(ii)). Response: Refer to other sections of this analysis.

3. Cut blocks, patches, or strips are shaped and blended to the extent practicable with the natural 

terrain (16 U.S.C. 1604 (g) (3) (F) (iii)). Response: Small patch openings will be blended and 

feathered to avoid straight edges.

4. Cuts are carried out according to the maximum size limit requirements for areas to be cut during 

one harvest operation (FSM 1921.12e). Response: The small openings are well under the 40 acre 

limit with the largest opening proposed at 10 acres. 

5. Timber cuts are carried out in a manner consistent with the protection of soil, watershed, fish, 

wildlife, recreation, esthetic resources, cultural and historic resources, and the regeneration of 

timber resources. Response: Refer to the other sections of this analysis.

6. Forest lands are harvested according to requirements for culmination of mean annual increment of 

growth (CMAI) (16 U.S.C. 1604 (m); FSM 1921.12f; FSH 1909.12, ch. 61.3). Response: This 

project proposes primarily thinning although some openings are proposed up to 10 acres in size. 

These openings are proposed where decadent (trees infested with bark beetles, disease, or declining 

growth) patches of lodgepole exist. Lodgepole is a short-lived species and these areas are 

generally 110 years or older and have reached CMAI. Other areas proposed for treatment include 

Douglas-fir that is heavily infested with dwarf mistletoe and has reached CMAI.

Suitability for Timber Production

The Forest Plan designates lands as generally suitable for timber harvest and timber production. These 

lands are validated at the project level (36 CFR 219.12(a) (2) (D) (ii)). Project level suitability 

determinations are made during silviculture, soil, and hydrologic field review and diagnosis. As a precursor to the silvicultural diagnosis process, stand examinations are conducted to determine existing stand 

conditions, and suitability for timber production. Final suitability determinations for lands proposed for 

commercial timber harvest would be documented in a site-specific silviculture diagnosis and prescription, 

prepared or reviewed by a certified Silviculturist, in coordination with the Soil Scientist and Hydrologist. 

In addition, the Forest Plan (1987) initially determined Douglas-fir/ninebark habitat types as unsuitable 

because of regeneration concerns. The assumption was that Douglas-fir stands with high dwarf mistletoe 

infection levels would need to be clearcut to promote healthy regeneration; however, the soils were too 

rocky to hand plant. The alternative shelterwood harvest system relying on natural regeneration would not 

be biologically acceptable because the infected Douglas-fir overstory would infect the Douglas-fir 

regeneration with dwarf mistletoe (Bitterroot NF 1981). The Forest Plan Monitoring and Evaluation 

Report, Fiscal Year 2003 (USDA Forest Service 2003b), states that previous monitoring of Douglasfir/ninebark habitat types determined that these sites should actually be classified as suitable. Proposed 

treatments in these habitat types are intermediate harvest treatments, not regeneration harvests. 

Stands proposed for harvest treatment in Lower West Fork were examined for suitability in accordance 

with 36 CFR 219.12(a) (2) (D) (ii). Using the following criteria, the units are suitable for timber 

management:

Ø Meets the definition of forestland as described in 36 CFR 219.16.

Ø Technologically feasible to ensure soil productivity and watershed protection. All sites 

considered for treatment would use established harvesting and site preparation methods. In 

combination with resource protection standards in the Forest Plan, applicable Best 
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-5

Management Practices (BMPs), and INFISH would be sufficient to protect soil and water 

resource values. 

Ø None of the stands considered for harvest have been withdrawn from timber production as 

specified in 36 CFR 219.12(2) (A) (B).

B. Bitterroot National Forest Plan Direction

The Bitterroot National Forest Plan (Forest Plan) (USDA Forest Service 1987) guides all natural resource 

management activities and sets out basic management direction. Forest Plan goals and objectives are stated

on pages II-2 through II-7 and Management Area (MA) direction is provided in Chapter 3. Goals and 

objectives directly applicable to timber management include:

Ø Provide sawtimber and other wood products to sustain a viable economy, including firewood 

for personal and commercial use.

Ø Provide an economically efficient sale program.

Ø Maintain forest stands so that pest caused losses are reduced to acceptable levels.

Ø Maintain vegetative diversity on land where timber production is a goal of management.

Ø Convert high-risk or insect and disease infected stands to young healthy stands.

Ø Provide optimal habitat on elk winter range.

Ø Provide for resource protection and fire use necessary to protect, maintain, and enhance 

resource values.

Ø Prescribe treatments that utilize integrated pest management strategies and treatments and

reduce long-term losses due to insects and disease.

The Lower West Fork project area contains nine of the 18 MAs allocated in the Forest Plan. Proposed 

activities are consistent with MA goals. Commercial timber harvest is proposed only in areas defined as 

suitable for timber management under the Forest Plan. Except where site-specific Forest Plan Amendments 

are proposed, all treatments are designed to meet Forest Plan Standards and Guidelines.

3.2.3. AFFECTED ENVIRONMENT

Vegetation is described relative to the process that shaped its evolution and in terms of its attributes, 

composition, and structure. Describing trends and the wide range of vegetation conditions that resulted 

from historical processes helps provide the context to evaluate current conditions. Understanding 

ecological processes and the effects of management activities defines desired stand conditions.

A. Existing Condition of Forest Structure and Composition 

Ecosystem-based management assessments focus on sustaining natural processes and promoting long-term

forest health to produce sustainable flows of goods and services to meet public needs. This strategy 

requires an understanding of ecosystem function, composition, and landscape ecological processes. A 

healthy ecosystem is more resilient to natural and human-caused disturbances and less vulnerable to

irretrievable losses.

Vegetation Response Unit

The vegetation response unit (VRU) is the basic environmental stratification for relating repeatable 

landscapes to predictable ecological processes (USDA Forest Service 1999). It provides a way to interpret 

vegetation response to natural disturbance processes and enables a projection of future landscape 

conditions, and a foundation for landscape design. We can anticipate management opportunities to achieve 

desired conditions with an awareness and understanding of disturbance ecology, the role of disturbance in 

ecosystem dynamics, and the appreciation that ecosystems are constantly changing. To ignore disturbance 

or presume steady condition only compromises ecological resiliency.

The VRU is an aggregation of land with similar biological capabilities, management potentials, and natural 

disturbance processes (USDA Forest Service 1999). These units have similar patterns of potential plant 
Affected Environment & Environmental Consequences – Silviculture

3.2-6 Lower West Fork Project Final EIS 

communities (habitat types), soils, hydrologic functions, landforms, and natural disturbance processes. The 

Region 1 habitat groups (Pfister 1977) are the foundation for the VRU classification. The combination of 

climate, and geophysical and soil features form the indicative habitat types of the ecosystem. Habitat types 

are assigned to Fire Groups, which are based on the response of the dominant tree species to fire and the 

roles of these trees species through succession (Fischer and Bradley 1987). Also, the historic fire regime of 

a given ecosystem can be characterized by the average fire frequency, fire intensity, and fire size (Perry 

1994)

The interaction of these processes creates a vegetation mosaic across the landscape. Within a VRU, the 

proportion of age and size classes, successional stage, and impacts of fire and disease change in response to 

disturbances. These changes directly or indirectly affect other aspects of the environment such as wildlife 

populations, biological diversity, insect pest populations, and fire potential and behavior. VRUs have a 

natural scale of disturbance, and management should mimic the typical disturbance scale of the particular 

VRU.

Disturbance strongly influences individual species, natural communities, and ecosystems, and can be 

attributed to both natural and human causes (Landres et al. 1999). Fires historically burned in a range of 

sizes, intensities, and intervals throughout an area and resulted in a mix of stand ages, structures, and 

species. Insects, forest pathogens, and other disturbances also changed vegetation through time. This 

diversity of vegetation across the landscape is desirable because forest conditions are more resilient to 

disturbance since not all size and age classes are subject to the same disturbance processes. Most of the 

treatments are proposed in VRUs 1, 2, and 7; and some treatments are proposed in VRUs 3, 8, 9 (Table 3.2-

1). No treatments are proposed in VRUs 4, 10, 11 (Fig. 3.2-1).

Table 3.2-1: Vegetation Response Units (VRUs) within the Lower West Fork Analysis Area

1

Old Growth Habitat as defined by Green et al. (1992 Errata 2005)

Vegetation Response Unit 1 is characterized by a warm, dry climate and mix of forested and non-forest 

sites. Where tree cover is present, it is composed of large ponderosa pine in open park-like stands with 

grassy understories and occasional shrubs. The density and distribution of Douglas-fir understory and codominant trees varies directly with the degree of fire exclusion. Lodgepole pine are largely absent on most 

sites due to high temperatures and lack of moisture. 

A natural fire interval of 5 to 25 years maintained the grassy open areas. These non-lethal, non-uniform 

burns regularly interrupted Douglas-fir succession and maintained ponderosa pine as the dominant stand 

Habitat 

Group

Old 

Growth 

Habitat1

Climate Modifier

(Region 1 Groupings)

Vegetation 

Response 

Unit

Primary 

Fire Group 

Code

Area

(acres)

Analysis 

Area

(%)

Purposed 

Treatment

(%)

HG 1 A Warm and Dry VRU 1 2, 4 2,286 7 11

HG 2 B, C Moderately Warm and 

Dry VRU 2 6 15,727 45 64

HG3 C, G Moderately Warm and 

moderately Dry VRU 3 6, 11 696 2 5

HG4 D Moderately Warm and 

Moist VRU 4 11 10 0 0

HG 7 E Cool and Moist VRU 7 9 4,574 13 12

HG 8 F Cool and Wet VRU 8 9 50 0 1

HG 9 H Cool and Moderately 

Dry VRU 9 7, 8 9,014 26 7

HG 10 I Cold and Moderately 

Dry VRU 10 10 946 3 0

HG 11 J Cold VRU 11 10 200 <1 0

- Non-Forest Scree N/A — 1,505 4 0
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-7

Figure 3.2-1: Vegetation Response Units (VRU) in the Lower West Fork Analysis Area.
Affected Environment & Environmental Consequences – Silviculture

3.2-8 Lower West Fork Project Final EIS 

component. During fire-free periods, dense thickets of Douglas-fir develop beneath the overstory. Fire 

suppression has extended the fire free interval allowing the Douglas-fir thickets to develop and create 

ladder fuels capable of carrying ground fires into the overstory crowns. Although rare, this condition can 

cause severe stand replacing fires. Fuel loads on representative habitat types of Fire Group 2 and 4 ranges

from 5 to 9 tons per acre and are composed of herbaceous material, tree litter and some large woody fuels 

(Fischer and Bradley 1987). Approximately seven percent of the analysis area is in VRU 1.

Vegetation Response Unit 2 is moderately warm and dry but is a transitional setting that includes warm, dry 

grasslands and moderately cool, dry upland sites. The dry, lower elevations are a mix of Douglas-fir and 

ponderosa pine in well- to over-stocked stands with increasing levels of Douglas-fir regeneration in the 

understory. Many units are greatly overstocked with Douglas-fir ladder fuels. Also, dwarf mistletoe 

infests much of the Douglas-fir and increases tree mortality in many units.

On the higher elevation, moist sites, the ponderosa pine component decreases, and a mix of Douglas-fir and 

lodgepole pine are more common. Ponderosa pine is more prevalent on southern and western aspects. 

Lodgepole pine is distributed in pure pockets across the VRU. These dry sites are mostly within the 

Douglas-fir habitat series. 

Fire group 6 is the primary group in this VRU. Prior to fire suppression, fire was an important agent in 

controlling density and species composition in this VRU (USDA Forest Service 1999). A non-lethal, low 

intensity fire is representative of the warm dry sites with a fire interval between 5 and 25 years. These low 

intensity fires burned in a non-uniform, mosaic pattern, generally consuming litter and undergrowth. They 

created an open, ponderosa pine and Douglas-fir overstory with small canopy gaps in which regeneration

developed. Structural diversity remained high under these mosaic conditions. Ponderosa pine was favored

because of its fire tolerance and ability to regenerate under these conditions (USDA Forest Service 1999). 

On the cooler and moister sites, a non-uniform mixed intensity fire burned every 15 to 45 years (Fischer 

and Bradley 1987). Stand replacement fires occur in the moist microclimates or overstocked stands where 

fuels increase during a fire-free interval of 150 – 400+ years (Arno et al. 1995). Topography, habitat type, 

and tree species mix influence the fire interval variability. Lethal fires typically occur in overstocked 

stands or draws where high fuel loads accumulate during the long fire-free intervals. A dense understory 

creates a fuel ladder that carries fire into the crowns and throughout the stand. Although not uniform or 

expansive, these patchy fires resulted in overall stand replacement with even-aged stands. Stand 

replacement fires are outside the representative range of variation for this VRU but need to be considered 

given the fuel loads in the existing stands and their predisposition to high intensity fires. Stand replacement 

fires are a larger threat on steep slopes because the ease with which the fire transitions from a ground fire to 

a crown fire. Because fire has been absent from this landscape, a larger proportion of the project area is 

predisposed to high intensity fires. Fuel loadings on representative habitat types of Fire Group 4 and 6 

averaged 11-12 tons per acre (Fischer and Bradley 1987). Approximately 45 percent of the analysis area is 

in VRU 2.

Vegetation Response Unit 3 and 4 are described as one unit because of their common features and limited 

extent within the analysis area. VRU 3 is moderately warm and dry, spanning the drier, warmer Douglasfir sites and warmer, moister grand fir sites, and has characteristics of each habitat type. The habitat types 

classified within this group typically occur on the well drained, lower to mid-slope benches and slopes. 

These VRUs contain highly variable assemblages of habitat types that reflect their wide distribution. Most 

of the habitat types are within the grand fir series and the cool moist Douglas-fir series. Douglas-fir is a 

major tree component of seral stands in all the represented habitat types. However, the mixture of tree 

species is equally distributed across the gradient of habitat types in both seral and climax stands. The tree 

species in these habitat types includes ponderosa pine, Douglas-fir, lodgepole pine, and grand fir. 

VRUs 3 and 4 represent about two percent of the project area, and treatment is proposed in five percent of 

the VRU. Habitat type groups in this VRU include Fire Groups 6 and 11, which is indicative of the 

complex fire regime for these transitional habitats. The diversity of fire regimes is due to the temperature 
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-9

and moisture variation between the habitat types. Overall, these VRUs have been shaped by a combination 

of fire regimes, which were mainly low to moderate intensity fires.

Research by Losensky (1993) in grand fir types of Idaho estimated historic fuel loads of 13-30 tons per acre 

in Fire Group 6. Other studies (Fischer and Bradley 1987) display a range of fuel loads that averaged 14 

tons per acre. While there is considerable variation within Fire Group 6, it tends to be overstocked and 

contain understory thickets that create potentially hazardous fuel conditions. In Fire Group 11, the 

estimated average fuel loads were 25 tons per acre. Because the habitats are moist, fire hazard is low to 

moderate despite the relatively high fuel loads under normal conditions. 

Vegetation Response Unit 7 occurs in the moist lower subalpine forest setting and is common on northwest 

to east facing slopes, riparian areas, and poorly drained subalpine sites. This VRU occupies a broad 

subalpine zone bordered by subalpine fir and lodgepole pine on cooler and drier elevations found in VRU 

9. Stand composition is often an overstory of Douglas-fir, lodgepole pine, Engelmann spruce, and small 

amounts of western larch with a dense understory of subalpine fir and some spruce.

Most habitat types in VRU 7 are in Fire Group 9 and a small percentage fall into Fire Group 7. Fire plays 

an important role in the development of species composition in this VRU. Estimated fire intervals are 

greater than 120 years for most sites (Fischer and Bradley 1987). Additional research demonstrates that 

non-uniform, infrequent stand replacement fires were the most common, occurring within a mosaic on low 

intensity and mixed intensity fires (USDA Forest Service 1999, Fischer and Bradley 1987). Arno (1980) 

estimated the fire interval at 100+ years in the lodgepole pine/Douglas-fir cover type. Non-uniform, mixed 

intensity fires were less common, but occurred at a frequency of 38-120 years in lodgepole pine/Douglasfir cover types (Losensky 1993). These types of fires resulted in large canopy gaps and mosaic conditions 

that included patches of even-aged stands, with surviving groups and individual trees.

Downed, dead, woody fuel average about 25 tons per acre but could be much higher (Fischer and Bradley, 

1987). This VRU comprises 13 percent of the analysis area.

Vegetation Response Unit 8 occupies very wet sites with a high water table associated with ravine bottoms, 

streams, springs, and wetlands. Most stands have old growth characteristics dominated by Engelmann 

spruce and subalpine fir. Most sites have such a high water table that species other than spruce cannot 

establish except on hummocks (USDA Forest Service 1999). Seral species, such as Douglas-fir, are 

represented, generally where some type of disturbance has occurred. Due to the very wet condition, the fire 

free interval can be very long. Intervals between severe, stand replacement fires are probably much longer 

than most of Fire Group 9 (Applegate et al. 1996). As riparian areas are very vulnerable to fire coming in 

from adjacent forested areas, it is desirable to manage fire in neighboring landscapes. Approximately 

0.01percent of the analysis area is in VRU 8.

Vegetation Response Unit 9 is cool and moderately dry with a short growing season and early summer 

frosts. Lodgepole pine is the seral dominant tree species in most stands, with Douglas-fir occurring as 

scattered overstory relics. Englemann spruce and subalpine fir are minor stand components, particularly 

where stand replacement fires have been absent. Whitebark pine may occur as a minor seral species. 

Within the analysis area, 96 percent of habitat types are within fire group 8. One habitat type is in fire 

group 7. The overstory of the dry, lower subalpine habitat type, subalpine fir/beargrass, is composed of 

mixed species and includes lodgepole pine. Research by Arno (1985) reported that 40 to 67 percent of 

mature stands in subalpine fir/beargrass habitat showed evidence of periodic underburns, particularly in 

upper elevations of the lodgepole pine cover type (Barrett 1982). Barrett (1982) found that fires originating 

at high elevations in these habitat types and fire group tended to be small and burn at low intensity. Stand 

replacing fires generally average 100 years with some mixed intensity burns occurring between 50-130 

years (Fischer and Bradley 1987). 
Affected Environment & Environmental Consequences – Silviculture

3.2-10 Lower West Fork Project Final EIS 

The average downed, woody fuel load is approximately 18 tons per acre but extreme fuel loads have been 

documented at 150 tons per acre (Fischer and Bradley 1987). Approximately 26 percent of the analysis 

area is within VRU 9 and treatment is proposed on seven percent of the VRU (Table 3.2-1).

Vegetation Response Unit 10 occurs in a transition zone between the forest and alpine tundra. It is typically

cold and moderately dry with short day lengths and receives low to moderate amounts of solar energy. It 

has a short growing season with early summer frosts. Many of these sites are above the cold limits of 

Douglas-fir and western larch. In the upper subalpine setting of western Montana, Abies lasiocarpa/Luzula 

hitchcockii (830) is the dominant habitat type (Pfister et al. 1977). Subalpine fir is the climax species with 

whitebark pine and Engelmann spruce as the principal species. The distribution of lodgepole pine is more 

prevalent where temperature and moisture conditions are moderate. Whitebark pine dominance increases

with elevation and site intensity (Smith and Fischer 1997). Within the analysis area, white pine blister rust 

and mountain pine beetle infestations have decreased the distribution and health of whitebark pine. Shade 

tolerant species are replacing whitebark pine. The ecology of whitebark pine is interwoven with that of 

lodgepole pine, mountain pine beetle, and western white pine blister rust. When beetle mortality is high in 

lodgepole pine stands, it is followed by high mortality in neighboring whitebark pine stands (Gibson 1994).

Fires are typically low to mixed intensity with fire intervals ranging from 35-300 years (Romme 1980). 

Most fires are low intensity because of discontinuous fuels (Arno et al. 1995). Mixed intensity fire is 

typical in stands with seral whitebark pine (Keane et al. 1992). Nonlethal underburns had an average 

interval of 56 years (Brown et al. 1993). In stands with more continuous fuels, stand replacing fire

frequency average more than 200 years. Stand replacing fires are most likely to occur when fires at lower 

elevations spread into the upper subalpine forests (Fischer and Bradley 1987). On the Bitterroot NF, 92 

percent of mature whitebark pine stands showed evidence of nonlethal underburns (Arno 1976). Fuels are 

relatively discontinuous with moderate to heavy loads of scattered, large diameter fuels. Fuel loads range

between 7 and 26 tons per acre (Fischer and Bradley 1987). Approximately three percent of the analysis 

area is in VRU 10.

Vegetation Response Unit 11 occurs on high elevation cold sites near timberline. Cold and dry conditions 

with short day lengths and low solar energy input are typical of these sites. In the analysis area, the 

predominant habitat type at timberline is whitebark pine/subalpine fir (Pfister et al. 1977). Habitat types at 

these high elevations are named for their dominant tree component rather than an indicated climax species. 

Whitebark pine is the potential climax species in this VRU rather than a seral species, as in VRU 10. 

Whitebark pine is very hardy at this elevation and out-competes subalpine fir. This habitat setting is above 

the cold limits for Douglas-fir, lodgepole pine, and western larch. Fuel loads and fire intervals are 

characteristically the same as VRU 10. Mixed intensity fire was typical of seral whitebark pine stands 

(Keane 1992). In the Selway-Bitterroot Wilderness, whitebark pine stands experience stand replacing fires 

every 180 years and non-lethal underburns average every 56 years (Brown et al. 1994). Fire appears to be a 

secondary influence on stand dynamics relative to environmental factors in the upper subalpine 

environment (USDA Forest Service 1999). Approximately 0.06 percent of the analysis area is within VRU 

11.

Losensky (1995) compiled the historic forest cover type for ecological subsection M332B stratified by age 

structure class (Table3.2-2). Current cover type stratified by age structure class was derived from the 

TSMRS database and is included in Table 3.2-2 to compare the historic and existing broad classifications in 

the Lower West Fork project area (PF-SILV-020). The historic data set included the entire Ecological 

Subsection M332B of almost 5 million acres. The existing condition percentages were calculated from 

National Forest in the Lower West Fork project area, about 35,006 acres of 38,376 acres total project area. 

The private land data was removed from the calculations. The area of the Lower West Fork data set is 

about 1 % of the total area of Subsection M332B. While a one to one comparison cannot be made due to 

differing scales of the data sets, accuracy of the historic data set, and accuracy and limitations of the 

Forest Composition
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-11

TSMRS data set, the general trends reflected in the table support trends through field reconnaissance of the 

project area by silviculturists and foresters. 

Table 3.2-2: Historic and Existing Forest Structure Class by Cover Type in the Lower West Fork Project

Area

1 Losensky 1995, Table 29, Age Structure in 1900 for Major Forest Cover Types.

2 TSMRS data using diameter class for comparison; DBH = diameter at breast height.

Overall, there has been a major shift in the sawtimber component, especially in Douglas-fir and lodgepole

pine. This increase in mature size classes is attributable in part to fire exclusion, which allowed Douglas-fir 

and lodgepole pine to be retained as stand components and reach maturity. Fire exclusion has prevented 

the periodic removal of understory vegetation, allowing it to mature, and increasing the stand density and 

competition for water and growing space. The existing stands are a product of succession in the absence of 

disturbance. Densities and species composition differ from historical conditions, as does the extent and 

continuity of this forest type across the landscape. The result has been a gradual trend toward the potential 

natural vegetation (the habitat type that would exist without disturbance). Higher densities of shade 

tolerant species are more prevalent, especially in the understory.

This shift in the seedling/sapling component means less area of the landscape is composed only of 

seedlings and saplings, and does not reflect that most of the mature stands have a dense seedling/sapling 

understory. The lack of structural diversity in the project area affects all cover types. Field observations 

indicate high departures from reference conditions in the smaller size class. This means that the 

seedling/saplings currently in the understory become the ladder fuels that carry ground fire into the forest 

canopy and increase fire intensity. 

The over-mature ponderosa pine structure class is not well represented in the project area relative to 

historic conditions, and there is a shift in cover types to the more shade tolerant species, specifically 

Douglas-fir. Though data in Table 3.2-3 indicate that ponderosa pine remains a strong cover type on the 

landscape, Douglas-fir is the dominant component and lodgepole pine and subalpine fir are increasingly 

represented. The fuel characteristics and loads that created the frequent, low intensity ground fires that 

favored ponderosa pine stand development have changed. Fires are more likely to be stand replacement 

fires with a high potential of killing the over-mature structure component, as well as, the smaller structures. 

Additionally, many of the plantations are heavily stocked and average more than 1000 trees per acre. 

Douglas–fir and lodgepole pine are competing with the planted ponderosa pine. Many of these stands are 

vulnerable to increasing insect infestations and disease rates because of the high stocking densities. 

Douglas-fir is the dominant cover type within the project area. It accounts for 44 percent of the forested 

land (Table 3.2-3). Lodgepole pine and ponderosa make up 16 and 22 percent of the forested land, 

respectively. Approximately five percent of the area is in the seedling/sapling structural stage, 18 percent 

in the pole stage, and 67 percent in the sawtimber structural stage accounting for 93 percent of the analysis 

area. The remaining 10 percent of the analysis area consists of non-stocked areas (PF-SILV-020). Mature 

ponderosa pine and Douglas-fir cover types would be the focus of proposed treatments in the project area

Cover Type 

(Losensky) Nonstocked

Seedling/Sapling

1-40 yrs1

Up to 4.9” DBH2

Poles

41-100 yrs1

Mature

101-150 yrs1

Over-Mature

151 yrs1

15” DBH +2

Historic

%

TSMRS

%

Historic

%

TSMRS

%

Historic

%

TSMRS

%

Historic

%

TSMRS

%

Historic

%

TSMRS

%

ponderosa pine 4 3 10 13 8 9 11 37 67 38

Douglas-fir 4 1 18 3 31 11 23 34 24 51

lodgepole pine 9 1 34 8 43 41 11 46 3 5

sub-alpine fir 0 <1 <1 7 20 44 24 43 57 6
Affected Environment & Environmental Consequences – Silviculture

3.2-12 Lower West Fork Project Final EIS 

(Table 3.2-3). Fifty-two percent of the treatment areas would be in the ponderosa pine forest type and 34

percent would be in the Douglas-fir forest type. 

Table 3.2-3: Existing Cover Type and Structure Class and Structure Class of Proposed Treatment Units 

in the Lower West Fork Project Area

1 Percent of the analysis area by cover type.

2 Percent of the treatment units by cover type.

Except for the Rombo fire area, there is a noticeable lack of variation in forest structure in the Lower West 

Fork project area (Fig. 3.2-2). Most of the area is mature Douglas-fir, lodgepole pine, and subalpine fir. 

The vegetation pattern appears as a homogenous cover type and size class broken by small, abrupt areas of 

past timber harvest, suppressed wildfires, or endemic bark beetle or disease incidences. The continued fire 

free interval has also changed the understory. This change has produced a decline in the availability, 

palatability, and abundance of many forage species. Shrubs and grasses, such as Scouler willow, western 

serviceberry, blue huckleberry, common snowberry, elksedge, pinegrass, and blue bunch wheatgrass, get

older and decline in the absence of fire (USDA Forest Service 1999, Fischer and Bradley 1987). 

Ecological processes and disturbances directly affect the diversity of plant and animal communities within 

an area over space and time. The better we understand this interrelationship, the better we will be able to 

plan our actions to maintain healthy, properly functioning ecosystems into the future. Ecological processes 

and disturbances include nutrient and biomass cycling, forest succession, weather events, insects, 

pathogens, fire, and human influences (i.e. timber harvest). The primary disturbances, or factors of change, 

influencing vegetation in Lower West Fork include, fire, insects, pathogens, and timber harvest.

Disturbance

Fire

Fire was historically the dominant agent of change and filled a very important role in Rocky Mountain 

ecosystems. Fires are natural modifiers of the vegetation, sometimes killing all trees and above-ground 

parts of vegetation (high intensity, lethal fire), sometimes killing only smaller trees or no trees at all and 

only burning understory grasses and shrubs (low intensity, non-lethal fire). Fires release nutrients to soils 

and streams, and affect the amount of dead, woody material and snags on a site. They affect soil moisture 

and stream-flows because of changes in the amount of available precipitation. They can also affect erosion 

processes and alter hill-slopes and stream channels when hard rains follow fires that consume forest floor 

organic soil layers before soil conditions recover. 

The historical frequency and intensity of fires was highly variable across the Bitterroot landscape, 

depending upon such factors as elevation, aspect, vegetation and fuel conditions, terrain, and weather. 

Most fires were lightning-caused. However, fires set by indigenous people living in this area before white

settlement played a large role particularly in the lower elevation forest types (Arno 1976, Barrett 1981). In

Forest 

Type

Nonstocked

(acre)

Seedling/Sapling

(acre)

Poles

(acre)

Mature

(acre)

Total Forest Type 

(acre)

(%)

(TSMRS) Analysis 

Area

Proposed 

Treatment 

Analysis 

Area

Proposed 

Treatment

Analysis 

Area

Proposed 

Treatment 

Analysis 

Area

Proposed 

Treatment

Analysis 

Area

Proposed 

Treatment 

ponderosa 

pine 255 16 833 362 663 257 5830 1986 7581(23)

1

2621

(52)

2

Douglasfir 109 18 1720 66 479 146 13009 1500 15317

(46)

1730

(34)

lodgepole 

pine 32 13 472 5 2347 48 2941 97 5792(17)

163

(3)

subalpine fir 18 8 236 28 1593 196 1745 182 3592

(11)

414 

(10)

Nonforest902

(3)

89

(2)
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-13

Figure 3.2-2: Forest Size Classes in the Lower West Fork Analysis Area
Affected Environment & Environmental Consequences – Silviculture

3.2-14 Lower West Fork Project Final EIS 

some of the drier ponderosa pine forest types, low intensity fires burn through the stand every 6 to 7 years 

(Arno 1976). Generally, as you move into the moister and cooler forest types, intervals between fires 

increase and the more severe, lethal fire becomes more common.

Several studies have found a marked decrease in the number of fires occurring in the Bitterroot Mountains 

since around 1920 and a corresponding increase in fire intensity (Arno 1976, McCune 1983, Brown et al.

1993). Possible reasons for this change are higher fuel loads, weather, and successful fire suppression, 

especially on lower intensity fires. Suppression of fire in these ecosystems during the 20th century may be

the factor affecting the largest proportion of vegetation across the Bitterroot landscape.

Insects and Pathogens

Susceptibility of forest stands to insects and diseases depends on a variety of factors such as species 

composition, size class, age, stocking, and environmental stress such as drought. Most insect and diseases 

are endemic and vital to the ecosystem. Stands outside historical conditions are at a higher risk for insect 

and disease related issues resulting in epidemic levels not sustainable in a functioning ecosystem.

In this section, those insects and pathogens that are of most concern and have had the most obvious 

influence on the forest within the Lower West Fork Project area include: dwarf mistletoe and bark beetles. 

Dwarf mistletoe 

Dwarf mistletoe (Arceuthobium douglasii) is a small, leafless, parasitic plant that extracts water and 

nutrients from conifer trees. These plants are native forest components and co-evolved with their host 

species. The effects of dwarf mistletoes on individual trees are gradual; therefore, the effects on ecosystem 

functions are gradual as well. 

Dwarf mistletoe species are generally host specific, occurring on one principal tree species. Douglas-fir is 

the major tree species affected by dwarf mistletoe in the Lower West Fork project area. Some dwarf 

mistletoe also occurs on lodgepole pine. The mistletoe plant causes brooms, stem cankers, stem and branch 

swelling on infected trees resulting in decreased height and diameter growth, reduction in seed and cone 

crops, and direct tree mortality, or predisposition to other pathogens of insects (Hawksworth and Wiens 

1996). 

Dwarf mistletoe spread rate is fastest in multi-storied stands where mistletoe seeds from infected overstory 

trees “rain down” on susceptible understory trees. Seedlings and saplings growing under a heavily infected 

overstory will be killed at an accelerated rate and will often die before reaching cone-bearing age. Brooms 

can contribute to development of ladder fuels leading to intense fire behavior (Hawksworth and Wiens 

1996). 

Most of the Douglas-fir in the analysis area is infected with dwarf mistletoe, with intensity rating of 4 and 

6. Huge witches’ brooms are common on these trees. The level of mistletoe infection in the younger 

Douglas-fir trees varies across the project area, from very low levels in some stands to very high levels in 

others. Where heavily infected Douglas-fir overstory exists, the infection level in the adjacent and 

understory trees is also high, and would be expected to continue to increase as long as the source of 

infection exist. Presumably, the effect of dwarf mistletoe adds to fuel generation rates and increases 

vulnerability of the forest to severe fire damage (Arno 1976). Alexander and Hawksworth (1975) found 

that as fire exclusion increased so did mistletoe infections, and that the re-introduction of fire would control 

the parasite.

Bark Beetles

Populations of mountain pine beetle (Dendroctonus ponderosae Hopkins), western pine beetle (D. 

brevicomis LeConte), and Douglas-fir beetle (D. pseudotsugae Hopkins), are currently low in the project 

area. However, forest conditions are suitable for populations to increase and cause tree mortality. Host 

tree species and size, and stand density create high-risk conditions beyond the historic range of variability. 
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-15

Mountain Pine Beetle 

Mountain pine beetle is the most aggressive, persistent, and destructive bark beetle in the United States. 

Mountain pine beetle attacks all western species of pine, native and introduced. The larvae feed on the 

inner bark and often kill the tree. Populations can build up to very high levels (epidemic) and cause largescale mortality when forest conditions are favorable (Amman et al. 1977). “High risk” conditions most 

typically occur in lodgepole pine when the trees are mature (average stand age >80 years), average stand 

diameter at breast height (DBH) is greater than 8”, and elevations are less than 6000’ (Amman et al. 1977). 

Events such as long term drought and other agents of stress such as high stocking levels, and root disease

increase stand risk.

Mountain pine beetle outbreaks are most devastating in stands that are:

Ø pure or nearly pure ponderosa pine

Ø essentially even-aged 

Ø 50-100 years old 

Ø average 8-12 inches DBH

Ø greater than 150 square feet per acre stem basal area (Amman et al. 1977)

At epidemic levels, the mountain pine beetle typically kills groups of pines, in both mature and in young 

overstocked stands. This beetle is often a primary cause of tree mortality, but can be a secondary cause, for 

example, in association with the western pine beetle or root disease. 

Reviewing past aerial detection maps from 2003 to 2005, mountain pine beetle activity was increasing in 

the analysis area and had the potential to be epidemic. In 2003, there were very few locations of mountain 

pine beetle activity. In 2005, mountain pine beetle locations were numerous and averaged more than 10

dying trees per location. The 2007 map indicated that mountain pine beetle populations were growing in 

the project area. Currently, there are several pockets of lodgepole pine mortality in some proposed units. 

Several stands have accumulations of mountain pine beetle-killed trees from past outbreaks. Lodgepole 

pine in the analysis area averages 110 years of age and the stands are overstocked with basal areas

averaging 180-200ft2/acre. Most of the lodgepole pine show signs of low vigor with poor growth rates and 

low crown ratios (less than 30 percent).

Douglas-fir Bark Beetle

Douglas-fir bark beetle is an aggressive beetle and also causes tree mortality. It generally attacks Douglasfir greater than 14” DBH in mature, dense stands but attacks smaller trees when Douglas-fir beetle

populations are very high (Negron et al. 1999). Wildfire, windstorms, and climatic stressors such as 

drought can trigger Douglas-fir bark beetle population increases. 

Within the analysis area, Douglas-fir is mixed with lodgepole pine and ponderosa pine. Aerial detection 

flights in 2003 showed few areas averaging more than 20 “fader” trees, trees dying from Douglas-fir beetle

attacks. The 2005 aerial detection map had a tremendous increase in the number of fader trees, averaging 

5-10 trees per acre. Walkthrough surveys conducted in the analysis area in 2007 noted Douglas-fir beetle

activity had decreased. This is also confirmed on the aerial detection maps for 2007. Much of the 

mortality is 2-3 years old and new attacks from this year were limited. Unlike other areas of the Bitterroot 

NF, the analysis area appears to have endemic levels of Douglas-fir beetle activity. During field reviews, 

many of the tree crowns that were red in 2005 and 2006 were less evident in 2007. Many of the large 

diameter Douglas-fir that died from Douglas-fir beetle attacks and were close to roads have been harvested 

for firewood.

Tree mortality is greatest in Douglas-fir or mixed-species stands that are mature to over-mature and densely 

stocked with a high percentage of Douglas-fir. Douglas-fir beetle predation plays a role in forest 

succession. When beetle populations are low or in forests containing minor amounts of Douglas-fir, the 

beetle will attack the larger-diameter Douglas-fir, particularly those weakened by other agents, effectively 
Affected Environment & Environmental Consequences – Silviculture

3.2-16 Lower West Fork Project Final EIS 

weeding out the mature trees. In seral Douglas-fir habitat types where stand composition is ponderosa 

pine, lodgepole pine, or western larch with minor amounts of Douglas-fir, the bark beetle would remove the 

Douglas-fir component and maintain the seral tree species. If Douglas-fir is the dominant tree species, the 

loss of scattered small groups or individual mature Douglas-fir creates openings. In grand fir, cedar, or 

subalpine fir habitat types where Douglas-fir is seral, the Douglas-fir beetle creates openings for the more 

shade-tolerant species to grow, transitioning the stand the climax stage (Negron et al. 1999). Changing one 

or more of the risk factors – host size, age, occurrence, and stand density is the best way to prevent bark 

beetle outbreaks (Hood et al. 2007).

The Douglas-fir beetle has consistently been associated with fire-injured Douglas-fir, often attacking larger 

trees with moderate to high levels of bole injury (Furniss 1965; Rasmussen and others 1996; Weatherby 

and others 2001) and light to moderate levels of crown injury (Cunningham and others 2005; Peterson and 

Arbaugh 1986; Ryan and Amman 1994; Weatherby and others 2001). Additionally many coniferous 

species have life history traits and characteristics that enhance their resistance to injury from fire, thereby 

increasing post-fire survival rates (Hood and Bentz 2007). Larger Douglas-fir are able to tolerate fire due 

to the thick insulating bark that develops with age and protects the inner cambium (Fowler and Sieg 2004). 

However, mortality following fire, not only depends on tree species, but also on type and degree of fire 

caused injuries, initial tree vigor, type, and intensity of fire and post-fire environment (Ryan and Amman 

1996).

Models are available to predict Douglas-fir beetle impacts from prescribed burning and post-fire

management after a wildfire. Models developed by Hood and Bentz (2007) predict Douglas-fir mortality 

and beetle attacks within four years post-fire in areas dominated by Douglas-fir in the Northern Rocky 

mountains. These models are intended to be a part of the planning process in Douglas-fir forests and 

managers should augment their decision criteria with information on many factors, including location of 

Douglas-fir beetle population centers, tree physiological factors, overall stand health, and management 

objectives (Hood and Bentz 2007). These models are used as a guide to manage treatment objectives and 

reduce Douglas-fir beetle effects on the forest.

Annosus Root Disease 

This root disease is widely distributed in North America, and harvest practices have increased its incidence 

and impacts (Rippy et al. 2005). The disease is spread by the fungus Heterobasidion annosum ((FR.) 

Bref.). Its primary mode of spread is by airborne spores landing on fresh cut stumps. The spores germinate 

and colonize the wood when conditions are favorable (Lockman 2006). The disease can also spread across 

root contacts if the neighboring tree is a susceptible species (Lockman 2006). This root disease often 

occurs in stands with other root diseases so root diseases are treated as a complex with the management 

recommendation of promoting root disease tolerant species. Ponderosa pine is the main host for the p-type 

Heterobasidion annosum ((FR.) Bref.) and mitigation measures would be applied to prevent annosus spread 

(Chapter 2). Fresh cut stumps of ponderosa pine would be treated with a borate compound, which prevents

the germination of annosus spores on the stumps (Lockman 2006). Also, preventing damage to residual 

trees during harvest would greatly reduce the incidence of annosus infection (Rippy et al. 2005). 

Stem Diseases

Western gall rust (Endrocronatrium harknessii (Moore) Hirat) is present in some lodgepole pine in the 

analysis area. It produces a gall, which affects form, growth rates, and kills individual trees. Some 

saplings and larger trees have flared target cankers called hip cankers. The only practical means of control 

is to thin out infected trees during stand treatments.

Western Spruce Budworm

Western spruce budworm (Choristoneura occidentalis Freeman) is an insect native to this area, and 

normally exists at endemic levels in the forest landscape. The larvae consume buds and foliage of 

Douglas-fir, subalpine fir, and spruce. Cones and seeds are also destroyed and tree growth can be reduced 
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-17

1960s, 

3681ac, 24%

1970s, 

3586ac, 24%

1980s, 

5834ac, 38%

1990s, 

1511ac, 10%

2000s, 536ac

4% Harvest By Decade

after several years of heavy defoliation. After four to five years, branch dieback, top kill, and tree mortality 

can occur.

Good budworm habitat consists of dense, multiple layers of host species. The upper canopy provides a 

good food source and refuge from predation, while the lower canopy intercepts budworm spinning from the 

upper layers and provides sanctuary from predators on the forest floor. The dense stand structure may also 

favor budworm survival by limiting the diversity of bird predators (Langelier et al. 1986) and reducing 

efficiency of some insect parasites.

Western spruce budworm has co-evolved with the forests of the Northern Rockies, and regular population 

fluctuations have always occurred. High population levels of the budworm periodically occur, largely 

influenced by climatic conditions. Though climate may influence the probability of an outbreak, stand 

conditions will determine the duration and intensity. Several studies have found that the intensity and 

duration of budworm outbreaks have increased over the past 50-100 years (McCune 1983, Stipe 1982,

Blais 1983, Carlson et al. 1983, and Anderson et al. 1987). It is probable that this change has come about 

largely because of past partial cutting and fire suppression practices, which has changed stand structures 

and species composition at the stand and landscape level (Schmidt 1985, Wulf and Gates 1987). Spruce 

budworm now has far more area of desirable dense, multi-canopied Douglas-fir forest available. 

Currently there are no known infestations of western spruce budworm in the stands within the analysis area. 

However, the structure and composition of many stands make them favorable to budworm activity and 

highly susceptible to infestation.

Timber Harvest

Timber harvest has occurred on

15,133 acres (43%) of the project area

(Fig.3.2-3, 3.2-4). Past harvest 

treatments since the 1950s include 

2,416 acres of intermediate harvest 

(commercial thin and improvement);

1,114 acres of clearcuts; 2,217 acres 

of seed tree and shelterwood harvest; 

715 acres of uneven-aged harvest; 

4,331 acres of pre-commercial 

thinning; and 4,340 acres of salvage. 

Much of this material was ground 

skidded or cabled yarded. 

Most of the timber harvest, 5,834 

acres, occurred in the 1980s and was 

yarded by cable, helicopter, or tracked 

vehicles. During the 1960s, 3,681

acres (24%) were harvested and 

planted when terracing was the 

primary site preparation method. Typical planting densities were in excess of 600 trees per acre, twice the 

initial stocking levels planted on the Bitterroot NF today. There are no records of thinning many of the 

terraces and stocking densities are relatively high. Many of the trees on the terraces are of commercial size

and showing signs of stress because of the high stand density.

B. Desired Stand Conditions 

The purpose and need for the project focuses specifically on: 1) reducing fuel loads in low elevation 

ponderosa pine/Douglas-fir forest, 2) improving forest resilience to natural disturbances by reducing tree 

densities in both young, regenerated stands and mature stands, and 3) maintaining or increasing shade 

Figure 3.2-3: Timber harvest by decade in the Lower West 

Fork Project Area 
Affected Environment & Environmental Consequences – Silviculture

3.2-18 Lower West Fork Project Final EIS 

intolerant species such as ponderosa pine. These objectives determined the desired stand conditions, which 

in turn helped formulate the silvicultural prescriptions that would shift the forest towards conditions more 

sustainable in the particular VRU. The landscape attributes are achievable under average conditions and 

are based on applied research, Interior Columbia Basin Ecosystem Management Project (ICBEMP)

findings, and local forest conditions. We combined some of the VRUs because they are a small percentage 

of the analysis area and have similar characteristics (Table 3.2-1). The desired stand conditions are as 

follows:

Vegetation Response Unit 1, 2 and 3:

Ø Desired forest structure reflects the product of frequent low to moderate intensity ground fires

Ø Stand conditions such as stocking, age class, and species composition create mosaics relative to 

the historic range of seral and climax tree species

Ø Non-uniform, open, mature ponderosa pine and Douglas-fir communities are sustained through 

prescribed fire and timber harvest at frequencies consistent with natural fire intervals 

Ø Implement prescribed fire at regular intervals across the landscape

Ø Favor early seral tree species when thinning dense, overstocked stands

Ø Species composition of approximately 70 - 85% ponderosa pine and 15 - 30% Douglas-fir

Ø Relatively low stand density, between 40 - 80 square feet of basal area per acre (ft2

/ac)

Ø Strive to maintain 15 - 25% seedling/sapling, 15 - 35% pole, 10-30% mature, and 20 - 35% 

over-mature structural stages based on ICBEMP findings (USDA Forest Service 1996)

Ø Create small openings (2 - 5 acre) within an irregularly shaped, treatment area (20 - 200 acre) 

to emulate variation that occurs from mixed intensity fires

Ø Maintain the vegetation health, vigor, stocking, species, and age class diversity 

Ø Average fuel loads generally range from 5 - 15 tons per acre

Vegetation Response Unit 7 and 8:

Ø Desired forest structures would reflect conditions of both mixed intensity fires and infrequent 

stand replacement fires

Ø Maintain historic fire frequency using prescribed fire or prescribed natural fire. Promote the 

development of fire-adapted species

Ø Generally, moderate stand density in treated stands with basal area between 80 - 140 ft2

/ac

Ø Species mixture should include 70 - 90% Douglas-fir and lodgepole pine and 10 - 30% other 

species 

Ø A variety of successional stages relative to historic ranges of seral and climax species

Ø Within this response unit strive to maintain 15-25% seedling/sapling, 20 - 40% pole, 15 - 30% 

mature, and 15 - 45% over-mature structural stages based on ICBEMP findings (USDA Forest 

Service 1996)

Ø Relic overstory would be aggregated or dispersed as stand conditions allow

Ø Average fuel loads generally range from 10 - 30 tons per acre

Vegetation Response Unit 9:

Ø Desired forest structures would reflect a mosaic of stand conditions similar to conditions 

created naturally by nonlethal and mixed intensity fires and low to moderately extensive stand 

replacement fires 

Ø Generally, moderate stand density in treated stands with basal area between 80 - 140 ft2

/ac

Ø A mix of even and multi-aged stands of Douglas-fir and/or lodgepole pine with stocking 

ranging from fairly open to dense with a mix of even-aged stands of lodgepole

Ø A variety of structural stages based on ICBEMP findings (USDA Forest Service 1996) – 20-

40% seedling/sapling, 40 - 60% pole, and 15 - 20% mature across the vegetation response unit

Ø Create small openings up to 25 acres to mimic past occurrence of mixed intensity fires

Ø Utilize prescribed fire where possible to maintain sustainable fuel conditions

Ø Average fuel loads generally range from 10-30 tons per acre
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-19

Figure 3.2-4: Past Timber Harvest in the Lower West Fork Analysis Area
Affected Environment & Environmental Consequences – Silviculture

3.2-20 Lower West Fork Project Final EIS 

Vegetation Response Unit 10 and 11:

Ø The desired forest structures would reflect the limited extent and variety of conditions caused 

by fire as a disturbance agent. The maintenance of a mosaic of pure and mixed species of 

various age and size classes would reflect the site capability and the historical pattern of fire

Ø Stand structures are relatively open and mostly uneven-aged

Ø A mix of patch sizes and an age/size class mosaic across the landscape

Ø The stand species composition would likely consist of pure or mixed stands of lodepole pine, 

whitebark pine, and Engelman spruce

Ø Species mixture should include 80 - 95% lodgepole pine and whitebark pine, and 5 - 20% 

Engelmann spruce, Douglas-fir and subalpine fir

Ø Endemic levels of insects and diseases 

Ø Average fuel loads generally range between 7 - 15 tons per acre

Noncommercial Thinning:

Ø Remove excess, damaged and diseased trees

Ø Reduce stocking levels to maintain or improve stand and tree vigor and reduce insect and 

disease vulnerability 

Ø Maintain stocking levels between 150 - 300 trees per acre

Ø Increase growth of remaining trees to provide a commercially valuable wood product

Ø Reintroduce fire into the older and larger diameter ponderosa pine

Ø Retain residual overstory trees for structural diversity

It is also important to ensure that potential treatments create healthy and sustainable forest and ecosystem 

conditions. The desired conditions should be within the range of natural variability – that which we might 

expect under natural disturbance and succession regimes. The desired future condition includes structures, 

compositions, and processes that would have been present historically. Fire is a natural process that 

provides many beneficial ecosystem functions. Thinning the forest before prescribed fire ignitions helps 

manage the fire intensity, and contain tree mortality within acceptable limits. Prescribed fire reduces forest 

vulnerability to severe and undesirable effects of future fire, insects, or disease. It creates a forest more 

resilient to environmental changes and able to provide a wide variety of resources to meet public needs. 

Timber harvest would be designed to maintain the larger diameter trees, which are better able to survive 

fires. Refer to the Fire and Fuels section (Section 3.3) for discussions related to the natural historic fire 

regime and the fire ecology of the affected stands. 

3.2.4. ENVIRONMENTAL CONSEQUENCES

This section describes the direct, indirect, and cumulative effects of the no action alternative and the two 

action alternatives.

A. Effects Common to All Alternatives

There are no specific effects common to all three alternatives with respect to the forested vegetation 

resource. To a certain extent insect and disease activity would continue with all alternatives, but at 

different intensities and scale depending on the alternative. Forest succession would continue, although at 

what stage would depend on which alternative is chosen.

B. Effects Common to Action Alternatives

Several effects are generally common to the action alternatives with the respect to forest vegetation. These 

effects are discussed in general terms and then more specifically by alternative.

The action alternatives propose some level of timber harvest, changing forest structure and composition

(Table 3.2-4). For both action alternatives there would be an effect on forest composition, structure, 

succession, and disturbance ecology. There would be less commercial harvest in sensitive watersheds such 

as Pierce, East Piquett, and Violet Creeks under Alternative 3 than Alternative 2. Under Alternative 3, 
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-21

commercial harvest would occur only in the WUI west of the West Fork River. The only commercial 

harvest on the east side of the River would be in the terraced plantations.

Table 3.2-4: Summary of Vegetation Management Effects by Alternative 

For all action alternatives, the spatial layout of treatment units would maintain mosaics of forest structure 

and composition. Patch cuts in lodgepole pine inclusions would reinitiate stand succession to the seedling 

structural stage. Relic overstory trees would be clumped or dispersed within the patch cuts but the young 

age class would be the main feature of the cut area.

Forest Composition

The commercial thin units would retain the larger size classes and mature, seral tree species. The objective 

is to improve the existing stands by featuring the largest diameter classes, promoting fire-resilient stands, 

and reducing the number of stems without any effort directed at regeneration (Smith 1962). Treatments 

would focus largely on the removal of small diameter trees and biomass, and follow-up mechanical and 

prescribed fire treatments. We recommend the use of prescribed fire as a tool to periodically reduce fuels,

as well as, restore and maintain vegetative composition and structure. For example, in VRU 2 prescribed 

fire used in combination with thinning prepares the site for maintaining ponderosa pine as a seral species.

Proposed treatments in both action alternatives would affect insects and pathogens. By decreasing forest 

density and competition, the remaining trees would have more light, water, and nutrients available to them. 

A healthy, vigorously growing tree has better defenses to resist insect and pathogen infections. Also, 

proposed treatments focus on removing infested or diseased trees. It is not possible or desirable to remove 

completely insects and pathogens from the ecosystem.

The effects discussion for each alternative describes the effects in each VRU.

Application of Borate

For all action alternatives, borate would be applied to cut ponderosa pine stumps greater than 12 inches in 

diameter. Retaining ponderosa pine in the project area is the main objective of this project. Ponderosa pine 

is also the main annosus root disease host. Once this disease becomes established, there is no economically 

feasible treatment to directly suppress it. Preventing its introduction is the most efficient and economical 

way to reduce its impact (Lockman 2006). To prevent the spread of annosus root disease, the freshly cut 

ponderosa pine stumps would be treated with a borate compound, which would prevent the germination of 

annosus spores that land on the stumps (Lockman 2006). Preventing damage to the residual pine would 

also greatly reduce annosus root disease infection (Rippy et al. 2005). 

The Forest Service completed a risk assessment of the borate or borax use (USDA Forest Service 2006g). 

The toxicologic agent is boron (USDA Forest Service 2006g). Boron occurs naturally in the environment, 

and exposure is unavoidable. Except for the most extreme exposure scenario considered in the risk 

assessment (the direct consumption of borate from a tree stump by a child), the use of borate will not 

substantially contribute to boron exposures in humans (USDA Forest Service 2006g). Health effects 

evaluations by the Forest Service have taken into consideration the potential for both worker and public 

exposure from this application. This information was used to formulate protective measures to reduce the 

risk to forest workers and the public (USDA Forest Service 2006g, Borax Pesticide Fact Sheet -

Affected Area Alt. 1 Alt. 2 Alt. 3

change stocking levels and improve resiliency 

(acres) 0 5,056 3,599

commercial treatment (acres) 0 3,056 2,163

non-commercial treatment (acres) 0 296 296

prescribed burning only (acres) 0 1,704 1,140
Affected Environment & Environmental Consequences – Silviculture

3.2-22 Lower West Fork Project Final EIS 

Information Ventures, Inc. 1995, and the borate Material Safety Data Sheet and Label - Wilbur Ellis 1996). 

The use of borate in Forest Service programs will not contribute substantially to boron concentrations in 

water or soil (USDA Forest Service 2006g). In addition, using borate to prevent the spread of annosus root 

disease is not a significant risk to wildlife species under conditions of normal use, even under the highest 

application rate (USDA Forest Service 2006g). Results from exposure scenarios indicate that aquatic 

animals and plants are not at risk (USDA Forest Service 2006g). Other mitigation measures such as 

riparian and wetland buffers would greatly limit any accidental spillage of large quantities of borate into 

aquatic habitats. 

Treatments Affecting Thinning Units

All ponderosa pine and lodgepole pine units must be thinned between July 1 thru December 31. Slash must 

be properly disposed of, i.e. piled and burned or lopped and scattered, to prevent population buildups of 

pine engraver (Ips spp.). Tree limbs and tops that exceed three inches in diameter need to be cut in fourfoot lengths and scattered so they dry out and do not become host sites for Ips beetles. 

Treatments Affecting Old Growth

Stand exams were performed to determine whether stands proposed for treatment classified as old growth

as defined by the Forest Plan and in Green et al. (1992). Stand treatments, including prescribed fire, in old 

growth stands will retain old growth structure and characteristics where they exist based on stand exam 

results. Members of the public have indicated that they view individual large, old, live trees and large, old, 

dead trees as old growth. Though these trees are components of old growth habitat they do not constitute 

all of the old growth characteristics as defined in the Forest Plan (USDA Forest Service 1987, pg. II-20). 

In this analysis, old growth classification is based on stand-wide structure and characteristics. 

Unit 70 is 200 acres, 154 of which overlap into the 1,042 acre Boulder Creek Research Natural Area 

(RNA). About 111 acres of this unit are old growth ponderosa pine forest (Fig. 3.2-5). We propose to treat 

unit 70 with prescribed fire in Alternatives 2 and 3. Recent field reviews by Forest Service resource 

specialists and research scientists, and scientists from the University of Montana documented the need for 

restoration management to preserve the old-growth habitat in Boulder Creek RNA (Steve Shelly Regional 

Botanist/Research Natural Area Coordinator Trip Reports for 5/29/08, 6/17/08, and 7/31/08). 

Treatment of Boulder Creek Research Natural Area (RNA)

The Boulder Creek RNA was established in 1991 for research, observation, and study. RNAs provide 

baseline areas for measuring long-term ecological changes and preserving genetic diversity (PF-SILV-013, 

page 29). The “major goal in the management of Boulder Creek RNA is the retention of outstanding oldgrowth forest representing several habitat types (upland and riparian)” (PF-SILV-013, page 15). “Fire, 

insect, and disease will be allowed to perform their natural role within guidelines that protect adjacent 

resources” (PF-SILV-013, page 16). 

Management direction in RNAs (FSM 4063.3.2) relative to logging and wood gathering states: “Do not 

permit logging or wood gathering activities in Research Natural Areas unless required for restoration of an 

area to natural conditions.” For vegetation management, the manual goes on to state: “Use only tried and 

reliable vegetation management techniques and then apply them only where the vegetative type would be 

lost or degraded without management. The criterion is that management practices must provide a closer 

approximation of the naturally occurring vegetation and the natural processes governing the vegetation than 

would be possible without management” (FSM 4063.34).

Old growth ponderosa pine in the RNA is vulnerable to wildfire from years of fire exclusion that has led to

Douglas-fir encroachment and accumulation of coarse wood. The Douglas-fir encroachment creates ladder 

fuels capable of transferring fire into the crowns. It also increases competition for limited water, which 

creates moisture stress and decreases tree vigor. These stressful conditions will intensify as climate 

becomes warmer and drier. Declining tree vigor predisposes the trees to bark beetle attack and disease. 

The unit also has high concentrations of irregularly distributed fuels, both as surface fuels and high crown 
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-23

bulk density. Fuels, especially duff mounds at the base of large, old pine, are deeper on the less steep part 

of the unit. Removal of the duff from the bases of the large, healthier pine would alleviate root or cambial 

damage from fire, especially on the more gentle slopes where fire would move at a slower rate. Where the 

slope steepens above 60 percent, fire would burn at a faster rate and fuels do not accumulate as deeply. 

This unit is vulnerable to stand replacement fire from the combination of high tree moisture stress and high

fuel loads. 

Rocky Mountain Research Station scientists met with West Fork Ranger District specialists in unit 70 

during the summer of 2008 to discuss stand conditions and management options. The scientists 

recommend initiating a prescribed fire program to rejuvenate the stand and reintroduce fire at an interval 

more aligned with the historic fire frequency. They believe this type of treatment would maintain the oldgrowth component and favor regeneration of ponderosa pine. They also note that stand density and fuel 

loads would need to be reduced before fire could be restored (PF-SILV-022). In the event of a fire, the 

scientists note that fire management would be constrained to full suppression in order to prevent it from 

spreading into the adjacent Wildland-Urban Interface. The full suppression fire management strategy 

would exacerbate the current stand conditions and the inevitability of a stand replacement fire and loss of 

the old growth ponderosa pine.

Treatment and Methods

The focus of treatment would be to protect large, mature ponderosa pine and promote ponderosa pine 

regeneration. This unit is in Fire Group 6 and VRU 2. Areas in Fire Group 6 have mixed intensity, surface 

Figure 3.2-5: Overlap of Boulder Creek RNA and Old Growth Stand Conditions in Unit 70 of the 

Lower West Fork Project
Affected Environment & Environmental Consequences – Silviculture

3.2-24 Lower West Fork Project Final EIS 

fires every 11 to 35 years. To mimic the historic fire regime, the unit fuel loads need to be reduced before 

igniting the prescribed fire. Ladder fuels need to be cut and the slash and debris removed from the bases of 

large trees. These pre-burn treatments would prevent long duration burning at the base of the trees and 

would keep fire from being carried into the crowns. We would also need to cut some large diameter trees 

to provide crown spacing and prevent any fire that gets in the crown from spreading through the crown. 

These treatments would protect the large, old ponderosa pine that have enough crown to support their

energy needs and the mature pine that continue to produce seed. Long duration burning and crown fire 

would kill these large pines. 

The focus of thinning would be to provide crown spacing of the residual trees and to create a more 

homogenous fuel bed. Creating space between tree crowns would reduce the potential a fire would be 

carried through the crown and a more even fuel bed would carry the surface fire uniformly through the unit. 

Thinning would remove the approximate number of trees per acre in the following diameter (dbh) size 

classes:

0-3" DBH 250 trees per acre (TPA)

3-9 "DBH 60 TPA

9-14" DBH 12 TPA

In addition, surface fuel and duff would need to be reduced by approximately 15 tons per acre. 

A combination of manual fuel treatments and prescribed fire would remove the excess fuel and restore the 

structure, composition, and function of the stand. Trees cut prior to burning would be slashed or slashed, 

piled, and burned depending on their density and proximity to large trees. The excess surface fuel and duff 

would be manually removed from the base of large trees, especially those capable of producing seed,

before prescribed fire ignition. Fuels would be treated on steeper slopes considering worker safety and the 

expected treatment benefit. Approximately 30 percent of the unit has slopes greater than 60 percent and 

talus rockslides, which present unsafe working conditions. Steep slopes, unstable footing, and rolling rocks

create dangerous conditions for operating chainsaws, felling timber, and igniting prescribed fire. 

Favoring ponderosa pine regeneration would also be a treatment objective since the existing pine 

regeneration is largely suppressed by Douglas-fir. Thinning would create a more even fuel bed to carry fire 

through the unit. Thinning slash and other fuels would be concentrated in the Douglas-fir thickets to create 

openings for ponderosa pine regeneration (PF-SILV-022). Natural ponderosa pine regeneration from seedproducing trees is desired in approximately 12% of the stand, which has very few large live trees (SILV023). The BA of these areas must have less than 40 ft2 BA after fire treatments to regenerate successfully 

(Fiedler 1996). Table 3.2-5 shows the approximate target treatment criteria of the existing and desired 

stand conditions based on four characteristics of old growth stand conditions. Fires would be implemented 

periodically, either as natural or prescribed fires, to maintain the stand development pattern and prevent the 

build-up of excessive fuels.

Table 3.2-5: Approximate Characteristics of Existing, Post Treatment, and Desired Stand Conditions in 

Unit 70

Species Composition TPA>15" BA>15"

Area of 

Ponderosa Pine 

Regeneration 

(acre)

Snags Down Wood

(Tons/acre)

Current 35%PP/ 55%DF/ 10% 

others 27 76 0 41 48

Post 

Treatment

70%PP/ 25%DF/ 

5% other 15-25 60-70 11 2-5 5-20

Desired 

Condition

70%PP/ 25%DF/ 

5% other 15-25 40-60 11 2-5 25
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-25

Monitoring

Forest Service scientists have established monitoring plots along transects in unit 70 to determine the 

effects of treating old-growth. Plots were established using R1 Old Growth Monitoring Inventory 

Protocols and data will be collected before and after treatment. A control plot was established to measure 

the effects of no treatment.

C. Alternative 1 (No Action)

Alternative 1, No Action, would not treat any stand in the project area; no areas would be harvested or 

prescribed burned. In the short term, there would be no immediate effects and the forest resource would 

appear unchanged. However, natural processes would continue and over time, there are effects and 

implications of implementing this alternative. Fire management options in and adjacent to the area would 

continue to be limited mainly to suppression for most of the fire season. The opportunity to use natural 

ignitions or prescribed fire would be hindered by the potential fire intensity, values at risk, and loss of large 

ponderosa pine trees.

There would be no direct effects on vegetation in the short term. The area would continue to change with 

natural forces determining stand conditions. The composition of the stand would change in direct relation 

to future disturbances. Ecosystem processes would continue and forest composition would change in direct 

relation to them. However, forest conditions would likely be very different from what they were 

historically. The potential natural vegetation in the analysis area is Douglas-fir and subalpine fir. Although 

this is the theoretical climax forest, it is not what existed historically because periodic fire maintained the 

seral species mix and structure. Eventually, fire would burn these stands. 

Direct and Indirect Effects

Commercial Thinning

While insects and pathogens are an inherent part of the forest, changes in stand composition, density, and 

structure would increase the vulnerability of these stands to infestation and mortality. Dense, multi-storied 

stands are susceptible to and capable of supporting populations of western spruce budworm and dwarf 

mistletoe infections. Areas that contain older, decadent lodgepole pine will experience mountain pine 

beetle mortality. Dense, continuous fuels will increase with increases in stand densities, tree decline, and 

tree mortality. The fire hazard will build and present conditions that favor high fire intensity and higher 

probability that fires will transition from surface to crown fires (Monnig and Byler 1992).

The multistoried stands of Douglas-fir are under stress from overstocking and heavy dwarf mistletoe 

infection. This creates the opportunity for Douglas-fir beetle, currently within the project area, to increase 

as trees vigor decreases. 

Noncommercial Thinning

We would not thin past regeneration units. Many of these forest plantations have successfully regenerated

into high-density stands. These stands are too dense to achieve optimal growth rate and size. Without 

treatment, they would be predisposed to insect and disease infestations (Graham et al. 1999) and stand 

replacement fire. In the fires of 2000, stands in similar conditions burned by rapidly spreading crown fire. 

Many of these stands are nearing the large size class of the pole structural stage. A fire would set them 

back to a seedling stage and make planting necessary. Stand density at the landscape level is not addressed

and the landscape would not move towards the desired condition without treating these units.

Without treatment, stand resilience would decrease and stand conditions would favor shade tolerant 

species. The relatively small area of these stands does not greatly influence fire behavior on a landscape 

scale. The investments made at the time of regeneration harvest would be lost if the anticipated 

intermediate treatments do not occur. The economic loss would be expressed through the decline in growth 

rate, and increased susceptibility to insects, disease, and fire that would extend the timber harvest rotation.
Affected Environment & Environmental Consequences – Silviculture

3.2-26 Lower West Fork Project Final EIS 

Prescribed Burning

In the absence of fire, shade-intolerant species such as Douglas-fir and subalpine fir would increase. 

Continuous, multiple vegetation layers of Douglas-fir with interconnecting crowns would continue to 

develop and increase the fire hazard. Stand structure would become denser and trees would be stressed for 

growing space and water. Ponderosa pine would decrease and eventually be replaced by shade-tolerant 

species. Native, fire-adapted shrubs, grasses, and forbs would decline. These factors would continue to 

interact and create conditions highly susceptible to fire. Low-intensity fire occurrence would be less likely 

because of the buildup of ladder fuels and downed woody material. The death of individual trees and 

clumps of trees will create canopy gaps. 

When fire does occur, it will most likely be of high intensity. The fires in 2000 burned in similar stands 

with many of the same vegetative conditions. Much of the area had 70-100 percent tree mortality. The

lack of seed, severe seedbed conditions, and competition from grasses and shrubs make regeneration 

extremely difficult. Invasive plants already present in the stands would increase relative to native species. 

Specific to unit 70 in the Boulder Creek RNA, lack of management would lead to further decline of the oldgrowth trees from small tree competition. The potential for a stand-replacing wildfire would also be very 

high. The consequence in either case would be a reduction in old-growth area on the Bitterroot NF (Shelly, 

2008). In addition, not treating this unit creates a corridor in which wildfire could move from the 

wilderness to the wildland-urban interface, and wildfire management tactics would be constrained to 

suppression. This situation would perpetuate conditions created by fire exclusion and increase the 

probability of stand replacement fires and the loss of large ponderosa pine trees.

The opportunity to manage natural ignitions and prescribed fire within and adjacent to the RNA would be 

hindered by the continued accumulation of fuels and the need to protect the ponderosa pine old growth. 

However, as fuels accumulate and old growth ponderosa declines, wildland fire would become increasingly 

difficult to suppress.

D. Alternative 2 (Proposed Action)

This alternative includes treatment combinations to change stand composition and structure using thinning 

and prescribed fire. There would be clear changes to forest composition, structure, and successional stages 

of treated areas under this alternative. This alternative proposes thinning overstocked stands and favors

more drought and fire resistant ponderosa pine trees, where possible. The treatment goal is to promote 

stand resilience to disturbance and stress factors, such as insects, disease, competition, and fire in the 

project area. The intent is to maintain insects and diseases at endemic levels and modify potential fire 

behavior. Proposed mechanical treatments followed by prescribed fire would create vegetative conditions 

where ecological processes interact as they have historically. Ecological processes such as fire are more 

catastrophic now than they were historically (Hessburg et al. 1994, Steele 1993) and harder to contain and 

control, which increases the risks to lives and property. 

Direct and Indirect Effects

Under this alternative, treatments would improve forest resiliency to insect and disease infestations, and 

fire. These proposed treatments would alter forest vegetation the most by increasing crown spacing, 

reducing stocking levels, and retaining large trees of fire-resistant species. Beneficial effects of these 

proposed treatments would be apparent for approximately 10-20 years. Even though treatments would 

reduce stand densities and lower risks of insect and disease infestation, vegetation growth rates would 

dictate when the risk level actually is reduced (Schmid et al. 1994). Reduction in stand densities would 

need to be an ongoing management practice in order to maintain forested conditions at a lower 

susceptibility level.
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-27

Noncommercial Thinning (approximately 296 acres; units 27, 75, 80, 82-85, 87, 91-98, 101 & 102)

Noncommercial thinning is proposed in predominately ponderosa pine plantations. These plantations have 

high densities of naturally regenerated species, including Douglas-fir and lodgepole pine, mixed with 

planted ponderosa pine. Thinning these stands will reduce competition for water, nutrients and light, and 

increase growth and vigor on residual stems. Thinning in the early “stem exclusion” stage effectively 

reduces stocking and redistributes growing space to the desirable species. Competition is high on these 

sites with high stem density and they are susceptible to mountain pine beetle and being destroyed by

wildfire (Graham et al. 1999). Trees growing within 12-18 ft. of saplings designated as crop trees will be 

cut and lopped with chainsaws, leaving approximately 150-200 trees per acre. Dominant trees with the

most vigorous growth and best form define the crop trees.

Many of these stands would remain even-aged though there is a scattered overstory of ponderosa pine and 

Douglas-fir. Many of the standing overstory Douglas-fir have severe mistletoe infections. In areas where 

the understory is predominantly Douglas-fir, these highly infected trees would be girdled during thinning 

and left as snags. Where the Douglas-fir understory is infected, many of these trees would be removed 

creating openings within the young stands. 

Stand density would be reduced by 30-60 percent in the thinning units. Treatments are designed to reduce 

fire hazard over the long term by rendering stands more resilient to natural fire occurrence and ecosystem 

processes. By reducing crown bulk density and changing species composition to more fire-adapted species, 

anticipated fire behavior will be more manageable in thinned stands in the long term. More open stand 

conditions are less prone to rapidly spreading crown fires than very dense canopies (Graham et al. 2004). 

This treatment will lower long-term fire hazard and tree mortality from insects and diseases. However, for 

at least the next few years there is high fire risk in these stands due to the amount of coarse woody material

generated and the low base canopy height. The fine fuels associated with slashing will break down in a few

winters and reduce the fire risk. After treatment, areas with high fuel accumulations would be hand piled

and burned. 

The Rombo fire of 2007 burned two of the proposed units, 92 and 93. These units are scheduled to be 

planted within the next year.

‘Lop and scatter’ treatment areas would be allowed from July 1 through December 31. This will allow time 

for larger boles to dry out and not become pine engraver beetle (Ips pini (Say)) host sites the following 

year. This is applicable to cut stems 3 inches or greater.

Overall, noncommercial thinning would enhance big game winter range habitat by reducing canopy cover

and allowing more sunlight to penetrate to the forest floor. High value forage species would have more 

growing space and become more productive. Increases in water yield would be minor since additional 

available moisture would be taken up by the residual stand. The treatment would increase stand resilience 

to disturbance in the long term and favor shade intolerant species addressing shifts in species competition 

that have occurred at the landscape level. The treatment would move the landscape towards the desired 

future condition. 

Prescribed Burning (approximately 1, 704 acres; units 32, 33, 60A, 61A, 63, 63B, 64-66, 69-74, 100)

Low intensity and mixed intensity burn units were identified because it is important that fire be restored 

and maintained as a process of change on the landscape. The use of prescribed fire is a desirable tool for 

periodic reduction in fuels as well as restoring and maintaining vegetation composition. In the low 

intensity burn units, current stocking levels are such that burning could be accomplished with minor 

residual tree mortality. Stocking levels would not appreciably change with this treatment therefore 

increased resiliency to insects and diseases would be minor. We need higher mortality levels in the mixed 

intensity burn units (Units 32, 33, and the upper part of 61A) to create openings in the forest canopy and 

expose mineral soil. Prescribed burning would recycle nutrients back into the soil where they would be 

available for uptake by residual trees. This flush of available nutrients would have some beneficial effects 
Affected Environment & Environmental Consequences – Silviculture

3.2-28 Lower West Fork Project Final EIS 

on trees. As long as the burn is accomplished within prescription parameters, insects and diseases should 

remain at endemic levels and not escalate to higher levels. There would be no commercial harvest in these 

units. To minimize impacts within sensitive watersheds, it will be important to increase RHCA buffers to 

at least 300 feet and allow fire to back into the riparian areas on its own accord without intentionally 

lighting the RHCA buffer.

Within VRUs 1-3, slashing material less than 7”DBH and the removal of duff or slash from large residual 

trees, especially ponderosa pine, could be needed to protect them from being killed during the prescribed 

fire. Slashing in advance of burning would minimize the radiant heat that could damage overstory trees. 

Duff accumulations are generally high around large ponderosa pine trees (over 12” DBH). Fire smoldering 

in the duff holds heat next to the tree bole and roots increasing the potential of tree mortality. Tree 

mortality, especially of large trees, is more often caused by the heat of fire smoldering in duff adjacent to a 

tree than from the fire intensity (per discussion with M. Harrington 10/2007). 

The extent of duff reduction, mineral soil exposure, overstory crown scorch, and tree mortality depends on 

the resource objective and fire prescription described in the silvicultural prescription. Prescribed fire will 

create favorable sites for natural regeneration though the intent is not to promote regeneration. To maintain 

open stand conditions, prescribed burning should be implemented every 5-10 years to ensure fire dependent 

processes are continued.

It is important to maintain downed woody material (greater than 3” diameter) at a level that would provide 

a source of nutrients and organic matter to support the growth of vegetation over time. Graham et al.

(1994) recommended between 5 and 30 tons depending on habitat type. This material would include the 

contribution of standing dead as well as woody fuels on the ground. These recommendations are designed 

to ensure nutrient and organic matter replacement over the next 100 or more years. This is particularly 

important on sites with light fuels and thin duff layers. 

In the mixed intensity units, which are at higher elevations, we want to create vegetative mosaics across the

landscape for several reasons. These include a diversity of wildlife habitats, diverse scenery, and reduce 

the probability of widespread wildfire damage to watershed values (Fischer and Bradley 1987). Research 

demonstrates that non-uniform, infrequent stand replacement fires were the most common, occurring 

within a mosaic of non-lethal and mixed intensity. Mixed intensity fires typically burn in patches due to 

discontinuous fuels that occasionally become crown fires, particularly on ridge tops (Fischer and Bradley 

1987). The objective of these burns is to create mosaics so fires are less likely to become crown fires. 

Specific to unit 70 in the Boulder Creek RNA, effects of treatment would be similar to those described 

above. In the event of a wildfire, there would be more opportunity to manage it as a surface fire and 

prevent it from escaping onto adjacent private property. Fire managers would have more options to 

manage fires beyond suppression. The opportunity to use fire within and adjacent to the area would be 

enhanced due to the reduction of fuel around the large ponderosa pines, improving the chances of those 

trees surviving.

Commercial Thinning (approximately 3,056 acres; units 1-26, 28, 29, 34, 35, 40-42, 60-62, 68, 81, 86, 88-

90, 99)

One of the intents of this project is to modify the factors associated with wildland fire behavior and effects. 

We cannot change slopes, aspects, general wind conditions, lightning strikes, or the time of day that a fire 

moves through an area. We can however modify fuels and therefore, change factors that affect fire 

behavior. Agee and Skinner (2005) state fundamental principles which are important for fuel reduction 

treatments: reducing surface fuels, increasing the height to live crown, decreasing crown density, and 

retaining large, fire-resistant trees species.

Commercial thinning within the project area would:

Ø thin the overstory from below and remove potential ladder fuels
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-29

Ø maintain a desired stocking level and provide more growing space for seral tree species

Ø maintain the large tree component of the overstory

Ø break up the homogenous and continuous horizontal and vertical structures 

Ø reduce the presence of less fire tolerant vegetation

Ø maintain stands in a low to moderate intensity fire regime.

The Rombo fire of 2007 burned five proposed treatment units (14, 15, 24, 26 and 88). The intensity of 

burn was analyzed by the Forest Service Remote Sensing Laboratory in Sacramento, California using the 

remote sensing program, RAVG. RAVG analysis indicates that 68 percent of the units burned at low 

intensity and 29 percent of the units were mixed intensity. The remaining three percent of the units burned 

at high intensity. Observations on the ground within the low intensity burn showed low amounts of tree 

scorch and mortality. The Rombo fire affected less than two percent of total acres being proposed for 

treatment within the project area. 

Overall, thinning treatments would reduce the number of trees currently found in the proposed units. Each 

proposed treatment unit has a unique mix of vegetation. Changes in vegetation through thinning would be 

most evident in areas with high stocking and multiple layer canopies and less evident in area with lower 

stocking. Thinning a multiple layered canopy would create a more open canopy, reduce the number of 

trees per acre, and keep the largest diameter trees as much as possible. We recognize that some large size 

trees would be cut and removed. However, a thinning from below is designed to start removing trees from 

the understory and then progress into the overstory until the desired spacing (or other prescribed outcome) 

is achieved. 

Lower stocked forests in the project area, for example plantations, appear more open and usually have a 

single canopy layer. These areas would retain an open appearance with reduced stocking levels once 

thinning was complete. Species diversity would be maintained within the units because other tree species 

would not be eliminated. Approximately 25 to 60% of the standing vegetation would be removed across 

the entire area of proposed thinning treatments. Thinning treatments are spatially arranged across the 

landscape.

The effects of commercial thinning would reduce the amount of shading on surface fuels, increase wind 

speeds and reduce relative humidity at the forest floor, increase the fuel temperature, and reduce fuel 

moisture. These factors may increase the probability of ignition and surface rates of fire spread over 

current conditions, depending on weather conditions, but the reduced fuel levels and arrangement of fuels 

would reduce fire intensity and increase opportunities for safe wildfire management. Surface fires, even 

higher intensity fires, are less likely to become crown fires when ladder fuels are reduced; reducing canopy 

bulk density also lowers the potential that individually torched trees would progress to crown fires. Lower 

overall fireline intensity would increase options for safe fire management (Van Wagner 1977, Rothermel 

1983, 1991). The proposed commercial thin treatments will raise canopy base heights, reduce crown 

density, and retain larger fire resistant trees within the VRUs. 

Prevention of insect and disease infestations is a pro-active approach that changes forest conditions from 

one that is susceptible to insect and disease to one that is less susceptible. This pro-active approach 

includes modifying vegetative conditions through silviculture practices that reduce tree-to-tree competition 

and remove stressed or unhealthy trees (Romme et al. 2006). Prevention is geared to reduce the risk of an 

attack getting started in a forest stand (Romme et al. 2006). Forest management is unlikely to prevent all 

outbreaks because of the infeasibility to manage intensively all forest stands as well as factors beyond our 

control such as drought and climate change.

Even though the Douglas-fir bark beetle outbreaks on the Bitterroot NF are declining (USDA Forest 

Service 2008), the proposed treatments would improve forest health conditions within the project area so 

there is less potential for future epidemic levels of Douglas-fir bark beetles. Ponderosa pine would be 

favored over Douglas-fir and a change in species composition, especially in the drier elevations would 

enable the remaining Douglas-fir to be maintained as a component on the landscape.
Affected Environment & Environmental Consequences – Silviculture

3.2-30 Lower West Fork Project Final EIS 

Removing Douglas-fir trees heavily infested with dwarf mistletoe would inhibit the spread of infection. 

Within a few treatment areas removal of all trees infected with dwarf mistletoe may be prescribed. Dwarf 

mistletoe is generally confined to a single tree species. Removal of the heaviest mistletoe infections and 

thinning that favors tree species not affected by Douglas-fir dwarf mistletoe, such as ponderosa pine, are 

management treatments that would be beneficial to overall stand health (Hadfield et al. 2000). With the 

removal of these trees, increased growing space would benefit the residual, more desirable species. 

Douglas-fir trees with lesser amounts of mistletoe would still be present on the landscape following 

treatment. Total eradication of dwarf mistletoe would not be possible or desirable.

Within VRUs 1, 2, & 3 stocking levels would vary with the site capabilities and would have an average 

basal area of 60 square feet per acre (ft2 BA). Stocking would be maintained between 40 and 80 ft2 BA. 

The classical basal area reduction (BDq) approach to stand structure regulation involves residual basal area, 

diameter of the largest reserve trees, and the ratio between the numbers of trees in successive diameter 

classes (Fielder, 1995). Fielder (1995) asserts residual basal area is probably one of the most important 

factors because it sets the stage for capturing the site potential, allocating space for regeneration, and 

ensuring structural sustainability. The target of 60 ft2 BA was based on site capability.

Small openings (2-5 acres) would be desirable in treatment units. These openings would create edge that 

would be beneficial to some wildlife species. Openings support the grass, forbs, and shrubs that are largely 

absent under canopy cover. Within sensitive watersheds, these openings would be reduced to about a 

quarter acre in size.

Overall, we expect there would be a balanced mix of shade intolerant species (ponderosa pine) and midtolerant species (Douglas-fir). Following treatment, the units would contain a mix of diameter classes and

trees would be well spaced. The long-term goal of this treatment is to maintain a range of age classes, 

create openings for regeneration, and adjust for mortality and accretion by allowing trees space to grow into 

different size classes. These intermediate thinning treatments would favor retaining the ponderosa pine 

component over Douglas-fir and have been successfully used on other areas on the Bitterroot NF. 

Treatments would leave fewer trees, reduce ladder fuels and crown bulk density, and break up crown 

continuity. The residual trees would be larger, have thicker bark and higher crown heights making them 

more fire resistant. These tree characteristics would reduce the crown fire potential and severe fire effects 

(Pollet and Omi 2002).

Thinning would decrease the risk of ponderosa pine tree mortality from mountain pine beetle and western 

pine beetle infestation by reducing stocking levels. This is even more evident on the terraced plantations 

where stocking levels are abnormally high and vulnerable to mountain pine beetle infestation.

Within VRU 7, 8, and 9, VRU 9 makes up the majority of the area. Stocking levels would promote 

resiliency and good tree vigor and average 80 - 140ft2 BA. Stocking levels would vary with site capability

but would not likely be reduced below 80ft2 BA. Stocking will be reduced approximately 30 - 60 percent. 

Intermediate treatments like thinning are a viable option in these VRUs where stand replacement is not the 

desired result. Thinning from below removes excess trees and opens up the growing space while 

maintaining a large overstory component. Target stands would be composed of lodgepole pine, spruce, and 

subalpine fir in cool, moist areas, and Douglas-fir and lodgepole pine in the lower to mid-elevations. 

Merchantable trees would be removed that are generally of poor vigor or competing with better quality 

trees. To reduce stand density, harvest would focus more on the smaller trees in the understory than the

larger trees in the overstory. 

Except in areas where openings are created, the proposed treatments would leave fewer, larger trees; reduce 

ladder fuels, and break up crown continuity. Reduced canopy bulk density, larger trees with thicker bark 

(depending on species), and higher crown heights would improve the chances of tree survival from 

subsequent fires and reduce the potential for crown fire occurrence (Pollet and Omi 2002).
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-31

Declining lodgepole pine would be removed where it exists to create openings for regeneration. Lodgepole 

pine is a short-lived, seral species that does not respond well to partial harvest. The lodgepole pine on these 

sites is often infested with dwarf mistletoe or mountain pine beetle. It is also highly susceptible to being 

wind thrown. Since lodgepole pine requires extensive levels of light to regenerate, openings will be created 

where lodgepole pine exists to allow natural reforestation. 

Prescribed Fire in Conjunction with Mechanical Treatments (all commercial units)

Prescribed fire is recommended as a tool for periodic reduction in fuels as well as maintaining vegetative 

composition and structure in all VRUs. Performing mechanical treatments in advance of prescribed fire 

allows fire to function in the project area without causing high levels of tree mortality. 

A mechanical treatment alone without the follow-up of prescribed burning does not alter wildfire behavior. 

Fuel load reductions would reduce fire hazard. Existing surface fuel loads and activity fuels would be 

reduced though consumption or removal to acceptable levels in combination of yarding and prescribed fire. 

Reducing surface fuels through prescribed fire and mechanical means reduces the risk that the overstory 

would ignite in a wildfire (Graham et al. 2004). Understory density and ladder fuels would be reduced 

through slashing where necessary to facilitate underburning and protect individual trees from scorch. 

Mechanical thinning and fuel treatments have been shown to reduce fire intensity and crown scorch (Pollet 

and Omi 2002). 

E. Alternative 3 

Alternative 3 was developed to address a variety of issues including sensitive watersheds and the changed 

condition of the project area from the Rombo Fire of 2007. The treatments and effects on the forest are 

similar to those in Alternative 2, except that some treatment units have been excluded. Therefore, the 

effects within the treated units are similar, but less area is treated and spatial effects across the project area

differ.

Direct and Indirect Effects

As in Alternative 2, Alternative 3 includes combinations of treatments that change composition and

structure through thinning and prescribed fire, however fewer units are treated. There would be clear 

changes to forest composition, structure, and successional stages of treated areas under this alternative. 

The biggest differences between the two alternatives are placement and type of treatment. Commercial 

harvest, except in the terrace units, and prescribed fire would occur on the west but not the east side of the 

West Fork River under Alternative 3. Treatments proposed in the terrace units would occur on both sides 

of the West Fork River. 

Noncommercial Thinning (approximately 296 acres; units 27, 75, 80, 82-85, 87, 91-98, 101 & 102)

Noncommercial thinning is proposed for the same plantations as in Alternative 2. These sites would 

benefit from thinning as described under Alternative 2. Thinning these relatively small stands on the east 

side of the West Fork River would not affect fire behavior on a landscape scale. An investment was made 

at the time of regeneration harvest that would be lost if the stands are not treated at this time. 

Prescribed Burning (approximately 1,140 acres; units 1 (part), 32, 33, 60A, 61A, 63, 63B, 70, &100)

Under Alternative 3, treating units with prescribed burning is proposed on the west side of the River. 

Prescribed fire is a desirable tool to periodically reduce fuels and restore and maintain vegetation 

composition. Current stocking levels in the prescribed fire only units are such that burning could be 

accomplished with minor levels of residual tree mortality. However, this will not be the case on the east 

side of the River if burning these units is delayed. Stand densities will increase and will ultimately need to 

be thinned before they can be burned. Higher tree mortality would be expected in the absence of treatment 

before the next fire. The Rombo Fire burned 12,918 acres in the analysis area and created diverse stand 

structure composition on the eastern third of the project area. However, the units identified for treatment 
Affected Environment & Environmental Consequences – Silviculture

3.2-32 Lower West Fork Project Final EIS 

are within the WUI, an area that the Rombo fire did not affect. Without treating the east side of the project 

area with prescribed fire there will not be a full complement of desired outcomes.

Commercial Thinning and Underburning (approximately 2,163 acres; units 1(part), 2-12, 14, 21, 25, 34, 

35, 61, 62, 81, 86, 88-90, & 99)

As in Alternative 2, proposed treatment units would change forest vegetation conditions by increasing 

crown spacing, reducing stocking levels, and retaining large trees of fire-resistant species. The treatments 

would increase tree vigor and enhance tree defense mechanisms to resist insect and disease attacks.

The reduction of commercial treatment is in response to the Rombo Fire, and the sensitivity of Piquett 

Creek, East Piquett Creek, and Violet Creek watersheds. The factors associated with fire behavior and 

effects would not be modified because the continuous, homogenous horizontal and vertical structures 

would be retained in the untreated units. The only proposed commercial treatment on the east side is within 

the terraced plantations. These terrace treatments and the effects of the Rombo fire do not spatially modify 

enough fuels across the landscape, which is an important effect on fire behavior. Without treatment, there 

will be no reduction in surface fuels, reduction in height to live crown, reduction in crown density, and the 

inability to maintain seral species such as ponderosa pine instead of shade tolerant species. Ponderosa pine 

will also become more vulnerable to mountain pine beetle and western pine beetle attack if stocking is not 

reduced in these units.

The effects of Alternative 3 on the west side of the River would be similar to those on the east side. Over 

time the consequence of implementing Alternative 3 would compromise forest composition and structure 

on the east side of the river.

F. Cumulative Effects

Potential cumulative effects were analyzed by reviewing past, present, and reasonably foreseeable actions 

in the Lower West Fork analysis area. Past harvest activities are listed by sale name where known. 

Historic timber sale records and the Forest Service Activity Tracking System (FACTS) database are the 

primary sources of this information.

Past Timber Harvest

Clearcuts, shelterwood, or seed tree harvest activities created openings in the forest since the 1950s (Table 

3.2-6). It is conceivable that additional harvest activities may have occurred that were not documented in 

the database. Desired tree species, such as ponderosa pine, were planted in the harvest areas. Current 

reforestation methods have evolved to hand planting with specific micro-siting and using local seed. 

Where shelterwood, clearcut, and seed tree silvicultural systems occurred in the analysis area, these 

activities served to break up landscape homogeneity by adding disturbance to the system (Fig. 3.2-4). This 

increased age class and species diversity by establishing young, shade intolerant stands. Terracing was also 

a popular means of regenerating stands following harvest in the past and a lot of this treatment occurred in 

the project area. Dozers were used to pile slash and create a stair step pattern of the terrace that allowed for 

machine planting. This planting method removed nutrients and coarse wood debris from the site and is no 

longer used.

Small tree plantations are stocked with young, healthy seedlings and saplings. These plantations are the 

primary contributor to the age and size class, and species diversity in the project area. Where regeneration 

harvest occurred, these sites have regenerated to the desired species and stocking levels from locally 

adapted seed. The action alternatives reduce fuels and establish healthy, vigorous stands. Of the action 

alternatives, Alternative 2 reduces fuels on a larger area than Alternative 3. Combined with past 

treatments, these alternatives increase productivity, vigor, and resilience on a greater landscape scale. 

Fuels are not reduced and stands are not thinned in Alternative 1 so the stand density would continue to 

increase and stand growth would slow. Stands may become increasingly susceptible to insects, disease, or 

fire or they may stagnate. 
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-33

Table 3.2-6: Past Harvest Activities -1950s through 2007

*Minimal data exists in some cases within the TSMRS data base or other records to determine the type of equipment used in a harvest 

treatment. Multiple types of equipment listed in the table for one treatment type infer that one or more units were harvest with that type of 

equipment. Many sales were unnamed prior the 1980s.

Past Planting, Site Preparation, Natural Regeneration and Timber Stand Improvement Activities

Post sale activities include planting, natural regeneration initiation, site preparation for planting or natural 

regeneration, and timber stand improvements such as slashing, release, or non-commercial thinning. 

1950s Harvest Activities

Sale Name* Harvest Method Type of Equipment* Acres

Unknown Clear Cutting Dozer Terracing 3

Total Acres Harvest Activities 1950s 3

1960s Harvest Activities

Sale Name Harvest Method Type of Equipment* Acres

Unknown

Clear Cutting Dozer Terracing 289

Intermediate Harvest 1,067

Shelterwood or Seed Tree Harvest 362

Salvage 922

Total Acres Harvest Activities 1960s 2,614

1970s Harvest Activities

Sale Name Harvest Method Type of Equipment* Acres

Unknown

Violet-Steep Creek

Clear Cutting 254

Intermediate Harvest 529

Shelterwood or Seed Tree Harvest 722

Uneven-aged Harvest 29

Salvage 616

Total Acres Harvest Activities 1970s 2,150

1980s Harvest Activities

Sale Name Harvest Method Type of Equipment Acres

Wheeler-Ward, Pierce Creek, 

Piquett Sanitation, Lavene, 

Beavertail, Violet Removal, East 

Piquett

Clear Cutting 372

Intermediate Harvest 130

Shelterwood or Seed Tree Harvest 1,133

Uneven-aged Harvest 449

Salvage 2,412

Total Acres Harvest Activities 1980s 4,496

1990s Harvest Activities

Sale Name Harvest Method Type of Equipment* Acres

Castle II, Lower West Fork, 

Christisen

Clear Cutting 196

Intermediate Harvest 480

Shelterwood or Seed Tree Harvest 0

Uneven-aged Harvest 237

Salvage 390

Total Acres Harvest Activities 1990s 1,303

2000s Harvest Activities

Sale Name Harvest Method Type of Equipment* Acres

Frasier Draw

Clear Cutting 0

Intermediate Harvest 210

Shelterwood or Seed Tree Harvest

Uneven-aged Harvest

Total Acres Harvest Activities 2000s 210

Total Acres Harvested since 1960s through 2008 10,802
Affected Environment & Environmental Consequences – Silviculture

3.2-34 Lower West Fork Project Final EIS 

Generally, reforestation treatments beginning in the 1960s through 1980s followed harvest activities on the 

same ground. In some cases planting followed immediately after harvest while in other areas, there was a 

time lag. In some areas, site preparation and planting activities were successful in enhancing growth of the 

new stand as well the reducing competition from shrubs, grasses, and non-desirable trees. Follow-up noncommercial thinning in 10 to 20 years reduced the number of trees, thus reducing competition, and set the 

stand up for the next round of commercial treatments. This is classic forest management to maximize 

growth and yield. 

In other areas, such as at higher elevations and in different timber types, natural regeneration was relied 

upon following harvest activities. Site preparation treatments may or may not have followed initial harvest 

activities. In areas where site preparation did occur, the results would be similar to planted areas. In areas 

where site preparation did not occur, shrubs and other plants competed with tree regeneration, and delayed 

full stand stocking and stand growth. 

Timber stand improvement usually occurred within the managed stands and consisted of spacing the 

desired trees, and lopping the thinned or slashed material. In more visually sensitive areas, piling the 

thinned material may have occurred and the piles burned. Currently, follow-up non-commercial thinning 

for timber stand improvement is difficult to accomplish due to budgetary constraints that creates a backlog 

of vegetative treatment needs. 

More recently, management focus has shifted from one of growth and yield to a desired condition reflective 

of the treatment objective. Within timber stand improvement projects this shift focuses on thinning the 

small diameter trees (ladder fuels), and reducing timber harvest created slash but keeping enough wood in 

the soil to replace nutrients. Thus, enough woody material is on the ground after treatment, such that 

follow-up burning is successful. 

Table 3.2-7 displays the planting, site preparation and timber stand improvement activities documented in 

the TSMRS database from the 1950s to the present in the project area. It is conceivable that additional 

post-sale activities occurred but they were not recorded in the database. 

Present Vegetation Treatment Activities Within This Analysis Area

Schoolpoint fuel reduction is a noncommercial thinning project with underburning in the analysis area. It is

under contract and treatments began in 2008. Thinning favors the most healthy individuals and desirable 

species for a given site. This would result in a cumulative benefit when considered in the context of the 

landscape with noncommercial thinning activities that are foreseeable within the analysis area. Under 

Alternative 1, stands would remain highly susceptible to mountain pine beetle attack and their ability to 

support stand-replacing fires would continue to increase over time. With Alternatives 2 and 3, the 

Schoolpoint fuel reduction project creates a landscape pattern of stand conditions in the project area that is 

more resilient to fire, insects, and diseases. 

Present Vegetation Treatment Activities Adjacent to This Project Area

The Trapper Bunkhouse Land Stewardship Project borders the northern edge of this proposed project. The 

purpose of the Trapper Bunkhouse project is to modify fire behavior in the urban interface and improve 

stand resiliency to insects and disease on 22,290 acres of the Bitterroot NF timber base. The adjacent 

Trapper Bunkhouse and Lower West Fork treatment areas would create a large buffer and provide 

continuous forest and fuel treatments adjacent to the WUI from Darby to West Fork. A mosaic pattern of 

stand structures would span the landscape and improve stand resilience and management options in the 

event of fires. 

Alternative 1 (No Action)

Cumulative Vegetation Effects by Alternative

No stand treatments would occur under the No Action alternative. Current ongoing work under contract as 

well as work planned and analyzed under other decision documents would still occur. Fires would continue 

to be suppressed according to Forest Plan direction. Without active management, long-term vegetative 
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-35

Table 3.2-7: Past Planting, Natural Regeneration, and Timber Stand 

Improvement Activities - 1950s through 2007

conditions would continue to deteriorate because of overstocked stands, and increasing susceptibility to 

drought, and insect and disease activity. Seral tree species would not regenerate as well under the forest 

canopy and shade-tolerant tree species would become more prevalent. Shade-tolerant tree species are not 

as resistant to fire, insects, and diseases typical of these lower elevation sites. The ladder fuels typical of 

these shade-tolerant forests increase the potential of large fire events and large-scale loss of forests. As 

time extends before a fire or insect outbreak occurs, the risk of large-scale forest loss increases. 

If a stand replacing or mixed intensity fire occurs, the resulting landscape would be similar to that which 

exists where the fires of 2000 burned the Bitterroot NF. Stand replacing or mixed intensity fires could 

create conditions that increase insect and disease population levels to epidemic levels. Bark beetle-caused 

tree mortality could increase following a large fire as occurred after the fires of 2000. This uncertainty is a 

1950s Planting, Natural Regeneration, Timber Stand Improvement Activities

Sale Name Activity Acres

Unknown Planting 55

Site preparation 0

Timber Stand Improvement 0

Total Acres of Activities 1950s 55

1960s Planting, Natural Regeneration, Timber Stand Improvement Activities

Sale Name Activity Acres

Unknown

Planting 264

Site Preparation 591

Timber Stand Improvement 1,041

Total Acres of Activities 1960s 1,896

1970s Planting, Natural Regeneration, Timber Stand Improvement Activities

Sale Name Activity Acres

Unknown

Planting 374

Site preparation 1,087

Timber Stand Improvement 1,338

Total Acres of Activities 1970s 2,799

1980s Planting, Natural Regeneration, Timber Stand Improvement Activities

Sale Name Activity Acres

Unknown

Planting 607

Site preparation 1,620

Timber Stand Improvement 1,338

Total Acres of Activities 1980s 3,565

1990s Planting, Natural Regeneration, Timber Stand Improvement Activities

Sale Name Activity Acres

Unknown

Planting 820

Site Preparation 1,996

Timber Stand Improvement 208

Total Acres of Activities 1990s 3,024

2000s Planting, Natural Regeneration, Timber Stand Improvement Activities

Sale Name Activity Acres

Unknown

Planting 0

Site preparation

Timber Stand Improvement 326

Total Acres of Activities 2000s 326

Total Acres post sale activity since 1960s through 2007 11,665
Affected Environment & Environmental Consequences – Silviculture

3.2-36 Lower West Fork Project Final EIS 

concern now because the Rombo Fire burned through the eastern third of the project area. Beetles can 

attack trees that were injured but not killed by fire, as well as trees that showed signs of low vigor for a 

variety of reasons before the fire, but were not directly damage by the fire (Hessberg et al. 2004). 

In addition, healthy trees in the beetle dispersal area can be mass-attacked as bark beetle population’s

increase in the low vigor and injured trees (Oliver and Larson 1996, Hessberg et al. 2004). These largescale disturbance events, fire and beetles, would change the forest character with the resulting landscape 

condition persisting for a long time. Natural regeneration would take longer than usual due to the lack of 

seed producing trees, and some areas may regenerate to less ecologically desirable species. Active 

reforestation to desirable tree species such as ponderosa pine would be dependent on the availability of 

funds to support such efforts. Ecologically, this impact would occur most in ponderosa pine since it is the 

most seral tree species. Forest Plan Goals and Desired Conditions would not be met for decades.

The impact of stand replacing disturbance events within VRUs 7, 8, and 9 would not be as ecologically 

severe since longer time intervals between disturbance events is characteristic of these groups. However, 

the vegetation currently existing on the landscape is reaching the upper limit of its disturbance interval. If a 

disturbance event occurs, the forest would be less resilient and the negative effects would cover a large area 

and be of long duration.

Alternative 2 (Proposed Action)

Long-term vegetation benefits are expected through proposed treatments by reducing forest stocking and 

favoring ponderosa pine. Fewer trees would improve individual tree health and vigor as there would be 

less competition for nutrients and water. We expect insect and disease infestations would be less severe in 

the event of a mixed or stand replacing fire because adjacent stands would have been thinned. However, it 

is difficult to predict precisely what may actually happen since many factors play into insect and disease 

epidemics and fire. 

As fire is managed on the landscape, we would expect some bark beetle activity in trees scorched by

maintenance and prescribed burning. The actual amount is difficult to determine but we expect it would be 

very small in scale and localized in the treatment units as long as burn prescription parameters were met.

Implementing proposed treatments within the main VRUs would allow managers flexibility to use wildland 

fire on the landscape knowing the treated vegetation is more resilient to insect and disease infestations and 

fire events. In addition, these treatments would work towards allowing fire to serve its ecological functions 

within fire groups 7, 8, and 9. The proposed treatments within fire groups 2, 4, and 6 would provide a 

place from which to support more active fire events upslope and into fire groups 7, 8, and 9. 

Beneficial effects of these proposed treatments would be seen for approximately 10 to 20 years. Even 

though treatments would reduce stand densities and lower risks to insect and disease infestation, vegetation 

growth rates would dictate when the risk level actually is reduced (Schmid et al. 1994). Reduction in stand 

densities would need to be an ongoing management practice in order to maintain forested conditions at a 

lower susceptibility level. In the future, we anticipate that additional maintenance treatments such as, 

thinning and prescribed burning would be needed to restore the historical fire interval and maintain forest 

resilience to fire, and insect and disease infestations. Prescribed fires 6 to 10 years after the initial 

treatments would maintain these beneficial effects. 

Alternative 3 

Like Alternative 2, we expect long-term vegetation benefits from the proposed treatments by reducing the 

forest density and favoring ponderosa pine. However, the treated area would be reduced especially on the

east side of the West Fork River in sensitive watersheds. The effects of not thinning units on the east side 

of the River could be seen in the near future as stands become more stressed by high stocking levels. As 

tree vigor declines, disease and bark beetle populations may increase to epidemic levels and kill the less 

stressed and vigorously growing trees.
Affected Environment & Environmental Consequences –Silviculture

Lower West Fork Project Final EIS 3.2-37

Not using prescribed fire to treat units on the east side of the West Fork River would increase the potential 

for high intensity fire behavior and provide very little if any flexibility for managing wildland fire on the 

landscape. The Rombo fire essentially treated the eastern portion of the project area mainly within the 

roadless area. The effects of the Rombo fire are very important across the landscape by providing 

vegetative diversity and mosaics. However, it is additionally important to treat the existing area especially 

within the WUI on the east side of the West Fork River since the Rombo fire did not burn that area. The 

fire created a buffer but did not go far enough to treat the east side.

3.2.5. CONSISTENCY WITH LAWS, REGULATIONS AND THE FOREST PLAN

Requirements for project or activity planning are established in the Forest Service Directives System. 

Required project level NFMA consistency findings are described in FSM 1900, Chapter 1920, Section 

1921.12-Vegetation Management Requirements and in FSH 1909.12, Chapter 20, Section 29-Application 

of Plan to Project. Forest Service Handbook 1909.12, Chapter 60, Section 61 describes Vegetation 

Management Requirements at the Project Level.
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Project Final EIS 3.3-1

3.3 FIRE AND FUELS

3.3.1 SCOPE OF ANALYSIS AND ANALYSIS METHODS

A. Area of Analysis

We analyzed the treatment effects on fuels and fire behavior across the entire Lower West Fork analysis 

area, which covers approximately 38,400 acres. The Lower West Fork analysis area contains thirteen 

named drainages: Pierce, Baker, Lloyd, Christisen, Piquett, Britts, Violet, Lavene, Troy, Boulder, Barn, 

Ward, and Wheeler Creeks (Chapter 1, Fig. 1.1-1). Approximately 42 percent of the project area, 15,832

acres is in the wildland urban interface (WUI). 

B. Analysis Methods

The purpose and need for fuels reduction in the Lower West Fork area as stated in Chapter 1 is: 

Ø Reduce fuel loads and lower crown fire hazard in low elevation ponderosa pine/Douglas-fir 

forests. These treatments would reduce fire intensities in the suitable timber base and WUI,

and increase fire management options to maintain fire as a landscape process. 

Fire is a natural force in ecosystems on the Bitterroot National Forest. By reducing fuel loads, we reduce 

the potential that fire would get into and spread through the forest canopy. Surface fire behavior is less 

extreme than crown fire behavior. It travels slower and does not burn as hot. The fire manager would have 

more time to evaluate resources at risk and plan a strategy that protects them while using the fire to 

promote natural resource objectives. Though we cannot control the ignition source, we can modify fire 

behavior by modifying available fuels. Reducing the potential for a crown fire would enhance firefighter 

and public safety, private property, and natural resources in the Lower West Fork area. To achieve this 

purpose, we need to reduce existing fuel loads by removing trees and excess down woody material, and 

restore the forest to a seral stage and fire regime more appropriate to the habitat. 

We use fire type as the indicator of treatment effects on fuels and fire behavior because of the relationship

between fire type, safety, and fire behavior (Rothermel 1983, Finney 2004, Van Wagner 1977). Fire type

categories are surface, torching, or crowning fire, and are based on fuel models, topography, and weather as

described in the following sections. 

Description

Fire Behavior – FlamMap 

Fuel reduction modifies fire behavior by reducing fire intensity and severity (Pollet and Omi 2002, Graham 

et al. 1999). By changing stand structure and reducing fuel loads, we reduce crown fire potential, fireline 

intensity, and rate at which a fire moves through an area. FlamMap is the model we use to evaluate 

changes in fire behavior resulting from fuel treatments. FlamMap calculates fire behavior characteristics 

based on fuels, topography, and weather (Rothermel 1972; Finney 1998).

FlamMap outputs are spatially explicit grids that display calculated fireline intensity and fire type category 

(no fire, surface fire, torching, or crown fire) at the resolution of input data. FlamMap outputs are 

calculated on a 30-meter-by-30-meter pixel basis; changes in fire type after proposed treatments are 

calculated as acres. 

Outputs

FlamMap uses several data layers including percent slope, aspect, elevation, stylized fuel model, canopy 

cover, canopy base height, canopy bulk density, and percent canopy cover. Weather is entered as a single 

event without any temporal variation and is represented by 20-foot wind speed in an “uphill” direction. 

Required Inputs
Affected Environment & Environmental Consequences – Fire & Fuels

3.3-2 Lower West Fork Project Final EIS 

The Lower West Fork analysis uses FlamMap to predict changes in fire behavior after fuel reduction 

treatments. These results are analyzed in ESRI ArcMap and Microsoft Excel.

Primary Use in Analysis

Assumptions and Limitations

The embedded fire behavior models in FlamMap assume constant weather, fuel continuity, constant fuel 

moistures, and that the fire is spreading in a steady state. The fire models were formulated as onedimensional point calculations, but have been utilized in two-dimensional spatial models using wave-front 

mechanics and Huygens’ Principle (Finney 2004). Finney (2004) details limitations and assumptions of 

fire growth modeling. Those assumptions and limitations are:

1. The landscape file data used in the analysis was obtained from LANDFIRE. The fuel and 

vegetation parameters were interpreted from 30-meter resolution LANDSAT satellite images 

captured during the summer of 2003 by scientists at the Missoula Firelab. Standard changes were 

made to layers representing the existing condition (PF-FIRE-002). Polygon layers defining 

proposed treatments guided development of raster layers used to reinitialize the FlamMap fuels and

vegetation layers for different alternatives (PF-FIRE-002). The modeling assumes that landscape 

vegetation changes since 2003 will not drastically affect modeling results, except for those 

resulting from the 2007 Rombo Fire, which were included into the existing condition, and the 

Frazier Interface and School Point Ecoburn activities, which were not included into existing 

conditions. We assumed the post treatment conditions of these two activities would reduce the 

potential fire behavior to surface fire. We also assumed treatments in Alternatives 2 and 3 would

be completed simultaneously, and regeneration processes would not immediately change the 

modeled effects of each Alternative. Though the treatments would not occur simultaneously, these 

assumptions allow us to compare the model results from the same basis and across a large 

landscape.

2. Fire shapes are assumed elliptical under uniform conditions. Other shapes have been explored and 

reported, but are not completely supported. Fire shapes in discontinuous fuels will not be 

adequately modeled. Final fire shapes are not an output in FlamMap, but the models use a series of 

fire ellipses to determine overall fire behavior. Because real fire behavior on a small scale is not 

the purpose of this model, this has little consequence on the results.

3. Fire spread rate and intensity at a given vertex is assumed independent of the fire and 

environmental interactions; modeled fires are not influenced by neighboring fires. In reality, fire 

behavior during large plume-dominated fires is controlled by the fire-environment interaction and 

cannot be modeled. Therefore, the model likely under predicts fire behavior during a plumedominated event or multiple large-fire events. This is a limitation of all current fire modeling 

efforts, but modeling of individual events is the best available science and has been used, with 

calibration, to model large fires.

4. Fire acceleration is assumed dependent on fuel type but independent of fire behavior. In reality, 

local environmental conditions may play a role in fire acceleration. Modeled fires may not be 

accelerated at the appropriate rate, but the effects of this on the outcomes of the model are not 

known. When modeling real-time fire events, this problem can be overcome through calibration; 

however, this calibration cannot be done for a hypothetical landscape modeling exercise.

5. Fires are assumed to instantly achieve the expected elliptical shape when burning conditions 

change (such as changes in wind speed or slope). This is an acceptable limitation for FlamMap 

because it does not incorporate a temporal element.

6. Elliptical fire shapes are assumed fuel independent; meaning fire shape (not size) is only 

determined by the wind-slope vector. Empirical relationships indicate fire shapes are common 

across many fuel types, so this assumption is not likely problematic for surface fire shapes. 

However, there is less evidence that this relationship is adequate for determining shapes of crown 

fires.
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Project Final EIS 3.3-3

7. Variation in wind speed and directions at a higher frequency than the wind stream resolution are 

assumed not to affect the elliptical fire shape, but this is incorrect. However, the importance of 

these fluctuations on overall fire growth and behavior is not known. Again, when modeling realtime fire behavior, calibration can be used to compensate for this assumption, but that is not 

possible for hypothetical landscape modeling.

8. The origin of an elliptical fire is assumed to be located at the rear focus of the ellipse. Some 

researchers suggest that this assumption has not been adequately examined, but it is still the 

approach most widely used. In reality, fire may spread faster down steeper slopes due to debris 

rolling downhill, but this is not considered in the models. 

9. The spread of a continuous fire front can be approximated using a finite number of points. This 

assumption is valid in continuous fuel beds. Landscape-scale modeling is somewhat coarse and 

therefore the model will bypass some spatial detail.

10. There is a poor estimation of fire spread where spotting, fire whirls, and fire induced atmospheric 

disturbances occur. These phenomena can be predicted but the areas of occurrence cannot yet be 

modeled.

Anticipated Consequences of Limitations

We considered the limitations of the FlamMap analysis listed above and determined they did not have 

substantial relevance on the comparative analysis of the alternatives. These analysis tools are sufficient to 

compare relative changes in fireline intensity, fire type, and arrival time to gauge the effectiveness of 

treatments in changing fire behavior.

3.3.2 REGULATORY FRAMEWORK

A. National Guidance

The Federal Wildland Fire Policy establishes standardized procedures and policies for federal wildland fire 

management agencies. The National Fire Plan directs a comprehensive approach to the management of 

wildland fire, hazardous fuels, and ecosystem restoration on federal land and adjacent state, tribe, and 

private forests and rangelands.

National Fire Plan

The National Fire Plan (www.fireplan.org) and 10-year Cohesive Strategy were initiated in 2000 following 

extensive wildland fires in the western states, including the Bitterroot Valley. The aim was to unite federal, 

state, and local fire managers and provide at-risk communities with a strategic plan to:

Ø Improve fire prevention and suppression

Ø Reduce hazardous fuels

Ø Restore fire-adapted ecosystems

Ø Promote community assistance.

Secondary priorities set by wildland fire policy include the protection of resources associated with the 

National Forest System. The General Accounting Office published a report titled, Western National 

Forests: Cohesive Strategy is needed to Address Catastrophic Wildfire Threats (GAO 1999). In the report, 

the GAO asserts, “The most extensive and serious problem related to the health of national forests in the 

interior west is the over-accumulation of vegetation.” In response to the report, the Forest Service adopted 

the Cohesive Strategy to reduce over-accumulated vegetation in the national forests. This strategy (USDA 

Forest Service 2000) established a framework that outlined four priority areas to promote the restoration 

and maintenance of ecosystem health in fire-adapted ecosystems:

Ø Improve the resilience and sustainability of forests and grasslands at risk

Ø Conserve priority watersheds, species and biodiversity

Ø Reduce wildland fire costs, losses, and damages

Ø And better ensure public and firefighter safety
Affected Environment & Environmental Consequences – Fire & Fuels

3.3-4 Lower West Fork Project Final EIS 

Specific guidelines for fire management are found in Forest Service Manual (FSM) 5100 (Fire 

Management) and multiple Forest Service Handbooks. Forest Service Handbook 5109.19 (Fire 

Management Analysis and Planning) gives specific direction on fire and fuels management planning 

practices.

FS Manuals/Handbooks

In 1995, the Federal Wildland Fire Policy and Program Review was initiated (USDI/USDA et al. 1995). 

Some of the principles of this review include: 

1. firefighter and public safety are the first priority 

2. wildland fire is an essential ecological process and natural change agent 

3. fire management plans must be based on the best available science

This policy directs the use of wildland fire and prescribed fire to restore fire’s natural role in appropriate 

areas where approved plans are in place. 

There are two guides to standardize procedures for implementation of the Federal Wildland Fire Policy and 

Program Review of 1995/2001: The Interagency Prescribed Fire Planning and Implementation Procedures 

Reference Guide (USDI/USDA 2008) and Guidance for the Implementation of Federal Wildland Fire 

Management Policy (February 2009).

B. Local Guidance

The Bitterroot National Forest Plan (Forest Plan) (USDA Forest Service 1987) includes forest-wide fire 

management direction that is consistent with other resource goals (Forest Plan Appendix M-1). The 

Bitterroot National Forest Fire Management Plan is an annually updated operational guide. For all fires, 

the priority is protection of human life, and firefighter, aviation, and public safety. Emphasis areas include 

improving prevention and suppression activities; reducing hazardous fuels – particularly around

communities, interface areas, and high-priority watersheds at risk; restoring fire adapted ecosystems; 

promoting collaboration among governments, communities, and stakeholders; and being accountable 

through performance measures and monitoring for results.

Bitterroot Forest Plan and Fire Management Plan

In pursuing these activities, firefighter and public safety are paramount, and decisions will incorporate 

sound risk management and consider economic viability based on values to be protected, costs, and 

land/resource management objectives. Based on the best available science, the role of wildland fire as an 

essential ecological process and natural change agent will be incorporated into the planning process at all 

levels.

Direction provided in the Forest Plan Appendix M-1, directs that fire programs be cost effective, 

compatible with the role of fire in ecosystems, and responsive to resource management objectives, 

including:

Ø Using prescribed fire to maintain healthy ecosystems that meet land management objectives

Ø Maintaining an adequate cadre of well-qualified prescribed fire experts to apply both technical 

knowledge and field experience in accomplishing prescribed fire objectives

Ø Emphasizing fire ecology when applying prescribed fire and using fire ecology reference 

documents

Ø Integrating the role of fire in silvicultural prescriptions to regulate stand structure 

Ø Emphasizing the use of prescribed fire in range and wildlife habitat improvement projects

Ø Allowing Wildland Fire Use (natural ignitions) within prescriptions to achieve resource 

management objectives, which provide for the protection of life, property, and adjacent 

resources to the extent possible

Ø Maintaining prescribed fire programs that are responsive to national, state, and local air 
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Project Final EIS 3.3-5

quality regulations and agreements

Ø Ensuring an active “inform and involve” program to enlist public involvement, understanding, 

and approval of prescribed fire programs

Fire is a valuable tool for reducing natural fuels and fuels generated from harvest operations. Fire 

treatments include broadcast burning, underburning, jackpot burning, and pile burning. These treatments 

are all necessary in fuels management. Prescribed fire is integrated into fire management planning through

NFMA and NEPA analysis where fire management objectives are defined and disclosed. Fuels 

management is based upon ecosystem management principles, processes, and desired conditions and the 

effects are analyzed at various scales (USDA Forest Service 1987, Appendix K-11). The Forest Plan 

requires full suppression responses only in Management Area 1 (USDA Forest Service 1987, pg. III-7). 

The full range of wildland fire management responses, from protection to resource benefit, is allowed in all 

other Management Areas (Forest Plan 1987, PF-FIRE-054). All fires are managed under the 1995 Federal 

Wildland Fire Policy (USDI/USDA 1995/2001).

Fire Management Units (FMU) defines the firefighters’ level of response to wildfires; FMUs do not dictate 

strategies or tactics for managing a fire. Tactics and strategies are addressed in the Forest Plan through

Management Area direction. The Bitterroot Fire Management Plan describes four FMUs but only three are 

in the analysis area. Strategic fire management objectives within these FMUs are: 

Ø FMU-1 Urban Interface (10,918 acres, 28%):

• Suppress those fires that have the potential to damage timber and/or property under current r 

predicted fire behavior and intensities. Under conditions where the objective of protecting 

timber and property values can be met, consider fire responses that will meet resource 

objectives. Provide for firefighter and public safety at all times. 

• During multiple fire incidents, prioritize initial attack resources to this FMU before all other 

incidences except in cases where potential threats to safety or values at risk are greater from 

fires in other FMUs. 

• Continue to plan and implement fuel reduction activities that alter fire behavior from high 

intensity and/or crown fire behavior to low or moderate intensity, surface fire behavior.

Ø FMU-2 Active Roaded (12,227 acres, 32%): 

• Suppress those fires that have the potential to damage timber and/or property under current or 

predicted fire behavior and intensities. Under conditions where the objective of protecting 

timber and property values can be met, consider fire responses that will meet resource 

objectives. Provide for firefighter and public safety at all times. 

• During multiple fire incidents, prioritize initial attack resources based on proximity to values at 

risk.

• Continue to plan and implement fuel reduction activities that alter fire behavior from high 

intensity and/or crown fire behavior to low or moderate intensity, surface fire behavior.

Ø FMU-3 Inventoried Roadless (12,083acres, 32%): 

• Routinely consider managing unplanned ignitions to meet resource and human value protection 

objectives. Provide for firefighter and public safety at all times. 

• During multiple fire incidences, prioritize initial attack resources based on proximity to values 

at risk. There may be instances when potential threats to safety and values at risk alter this 

prioritization.

Private Land makes up the remaining 8% (3,180 acres) of the analysis area.

The National Fire Plan and the 10-year Cohesive Strategy were the impetus behind the Bitterroot 

Community-Based Wildland Fire Risk Mitigation Plan (Community Wildfire Protection Plan). All Fire 

Chiefs in Ravalli County from city, rural, and federal fire departments, collaboratively developed and 

Bitterroot Community Wildfire Protection Plan
Affected Environment & Environmental Consequences – Fire & Fuels

3.3-6 Lower West Fork Project Final EIS 

adopted the Community Wildfire Protection Plan. The County Commissioners and Bitterroot National 

Forest Supervisor signed the document. The Community Wildfire Protection Plan

(www.bitterrootfireplan.info) prioritizes hazardous fuels treatment locations on the Bitterroot National 

Forest as directed in the National Fire Plan (PF-FIRE-001). The Lower West Fork Wildland Urban 

Interface is a “high” priority location based on values at risk and potential fire behavior. 

3.3.3 AFFECTED ENVIRONMENT

Understanding the past and present role of fire in the Bitterroot area is critical to understanding the area 

affected by the proposed action and the desired conditions for fire and fuels in this area. This section 

describes the current fire and fuel conditions relative to historic conditions and the consequences of 

departure from them in the Lower West Fork analysis area. It also describes the WUI and the potential and 

desired fire behavior. 

A. Fire Groups and Fire Regimes

Historically, wildland fire played a key role in shaping vegetation in the Lower West Fork area. A “fire 

regime” describes how fire naturally functioned in terms of extent, severity, and frequency in a particular 

place. There are several ways to characterize vegetation, fuels, and fire regimes depending on the 

application. In this document, we reference “fire groups” (Fischer and Bradley 1987) and fire regimes” 

(Hardy and others 2001). The association between these characterizations that describe vegetation and fire

processes in this and the Vegetation section 3.2 are shown in Table 3.3-1.

Table 3.3-1: Vegetation and Fire Descriptors 

Used in the Lower West Fork Analysis

Fire Group Fire Regime1

2 I

4 I, II

6 III

7 III

8 IV

9 IV

10 V 1 Refer to Table 3.3-2 for definitions

Natural and human-caused fires perpetuated fire-adapted plant communities, maintained ecosystem health 

and function, created vegetation mosaics, and reduced the potential of high severity, stand-replacing fires. 

Frequent, low severity fires were common at lower elevations while mixed to high severity fires burned 

less frequently at elevations above 6,000 feet in the Lower West Fork analysis area. Frequent fires

increased vegetative structure variability.

Historical fire regimes in the Lower West Fork analysis area had short to moderately short fire-free 

intervals, and were not typically stand replacing fires (Table 3.3-2). Non-stand replacing fire regimes

(Regimes I and III) represent about 64% of the Lower West Fork area and fire regimes with short fire 

return intervals (Regimes I, II) represent 55% of the area.

The abundant literature on fire history and fire ecology of western Montana, and specifically the Bitterroot 

NF, supports the conclusion that stand-replacing fires were not typical to most of this area (Barrett et al.

1997, Arno et al. 1995, Agee 1993, Fischer and Bradley 1987, Arno and Gruell 1986, Arno and Petersen 

1983; Habeck 1976, and Habeck and Mutch 1973). John Leiberg, who surveyed the Selway sub-basin in 

1897-98, indicated that approximately 35 percent of the surveyed area had burned within the previous 40 

years (Leiberg 1899). Arno (1976) found evidence in the West Fork and Tolan Creek drainages of the 

Bitterroot NF that fires of low-to-moderate intensity occurred most often over the landscape, with 

occasional stand-destroying fires. He found an average fire-free interval of 11-16 years in ponderosa and
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Project Final EIS 3.3-7

Table 3.3-2: Fire Regime Descriptions for the Lower West Fork Area (Adapted from Hardy et al. 

(2001) and Schmidt et al. (2002) 

Natural 

Fire 

Regime

Frequency 

(Mean Fire 

Return 

Interval)

Vegetation 

Severity

Portion of 

Analysis 

Area1

Description

I 0-35 years, 

Frequent 

Surface

Mixed 

25%

(9,667 Ac.)

Fires in Regime Group I generally create open stand 

conditions with small inclusions of higher density. 

Understories are generally sparse. Forest gaps result 

when individual trees and small groups of trees are 

killed. Localized, heavy accumulations of fuels heat 

some tree boles and roots to lethal temperatures. Standreplacing fires result when heavy accumulations of fuel 

are contiguous throughout the stand. 

II 0-35 years, 

Frequent 

Stand 

Replacing

30% 

(11,537 

Ac.)

Fire Regime Group II, found in grass and shrub types, 

has similar fire frequency as forested communities but

the intensity is much greater. Fire top-kills stands of 

grass and willow, but causes a "stand- replacing" effect 

in bitterbrush and mountain mahogany. In the 

grassland and willow communities, vegetation 

development often occurs from the re-sprouting of 

existing plants. Bitterbrush and mountain mahogany 

however, rarely resprout and fire in this community 

results in seral stages that are dominated by grasses and 

forbs

III

35-100 

years, 

Infrequent 

Mixed 

Surface

39%

(14,968 

Ac.)

Fire Regime Group III has a longer fire return interval 

than Groups I and II. Because disturbance occurs less 

often, vegetative density increases and fuel 

accumulates, resulting in fires of greater intensity and 

severity than Groups I and II. Larger areas of mortality 

generally result, creating more diversity in age and size 

classes on the landscape.

IV

35-100+ 

years,

Less 

Frequent

Stand 

Replacing

1% 

(369 Ac.)

Fire Regime Group IV has a fire frequency similar to

Group III; however, fires generally result in greater 

mortality because lodgepole pine stand densities, the 

dominant vegetative type in this fire regime, are higher 

than those found in the drier vegetation communities in 

Group III. Additionally, lodgepole pine, due to its thin 

bark, is less resistant to fire than those species found in 

Group III. Arno (1976) noted that large fires in the 

lodgepole pine communities and spruce-fir types 

historically resulted from a combination of high fuel 

loading, drought, and wind. He also noted that nonlethal fire may have occurred in lodgepole pine forests 

at some time between the stand replacing events, 

possibly at intervals as short as 40-80 years. 1

Approximately 1,797 acres or 5% of the analysis area is considered non-combustible (water, barren, or sparse)

Douglas-fir habitat types during the period 1734-1889. His fire maps show a pattern of frequent averagesized fires spreading, unsuppressed to about a square mile (640 acres). On average, a fire occurred in the 

drainage every seven years. The maps also showed that a very large fire, in excess of 4-square miles (2,560 
Affected Environment & Environmental Consequences – Fire & Fuels

3.3-8 Lower West Fork Project Final EIS 

acres without suppression actions), occurred approximately every other decade. These large fires were 

low-severity with some mixed-severity areas. 

One hundred and forty two ignitions, both lightning and human-caused, were recorded from 1970-2007 

within the analysis area (Fig. 3.3-1), ranging from 0-12 ignitions per year with an average of four (Fig. 3.3-

2, 3.3-3, and 3.3-4). Eighty one percent of the ignitions were lightning caused. At least partly due to 

effective fire suppression, these fires were generally small, and did not perform their historic role of 

reducing surface and ladder fuels.

According to fire history records of the analysis area, there have been eighteen wildfires over 100 acres in 

size since 1889. Most of these fires have been at the lower elevations of the analysis area primarily 

affecting ponderosa pine habitat types. The 2007 Rombo fire burned 29,062 acres; 12,918 acres are within 

the Lower West Fork analysis area. Most of the area burned in the Rombo fire was higher elevation 

Douglas-fir and subalpine fir habitat types, primarily in the Piquett Creek watershed on the eastern side of 

the analysis area. This is an important point given the current vegetation in-growth on the west side of the 

West Fork River from fire suppression and the extension of fire-free intervals from historic fire 

frequencies. 

Disruption of the natural fire regime can cause fire effects outside the natural range of variability. The 

vegetation composition, structure, and fuels in low-elevation ponderosa pine and Douglas-fir forest types 

are outside the natural range for the fire regime, and are at risk of losing key ecosystem components in the 

event of a wildland fire or requiring intensive suppression actions. Fires occurring in these forest types are 

highly uncharacteristic compared to the natural fire regime in terms of behavior, severity, and patterns. 

Typically, large fires occurring under these conditions are prone to crown fire behavior and stand 

replacement fire. 

Subalpine fir forests are located in some riparian and higher elevation sites within the analysis area. 

Vegetation composition, structure, and fuels in this forest type moderately depart from the natural regime, 

which also predisposes them to the risk of loss of key ecosystem components in the event of a wildland 

fire. Fires are moderately uncharacteristic compared to the natural fire regime in terms of behavior, 

severity, and patterns. Typically, large fires that occur under these conditions are subject to the range of 

fire behavior from surface to crown fire.

Fires have been suppressed on a large portion of the analysis area, which has extended the fire interval. 

Consequently, the potential for stand replacement, crown fires is higher than the historic conditions. This is 

because in the absence of fire, biomass has increased beyond historic conditions. 

B. Current Fire Behavior Conditions

Fire behavior is the manner in which a fire reacts to available fuels, climate, local weather, and topography. 

A change in any of these components causes a change in fire behavior (DeBano et al. 1998). “Extreme” 

fire behavior describes fire behavior characteristics that typically preclude using direct fire control

methods. One or more of the following is usually observed during times of extreme fire behavior: high 

rates of spread, high flame lengths, crowning fires, spotting ahead of the main fire, fire whirls, or strong 

convection columns. Such fires often behave erratically because they can influence the local fire weather, 

making a fire less predictable and more dangerous (Rothermel 1991). Fire behavior is most often 

characterized by fireline intensity (directly related to easily observed flame length), rate of spread, and fire 

type (Rothermel 1983, Finney 2004, Van Wagner 1977).

There is high potential for a large fire to occur in the Lower West Fork area. The 2007 Rombo Fire quickly 

escaped initial attack efforts, and threatened natural resources and private property. Even with readily
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Project Final EIS 3.3-9

Figure 3.3-1: Fire Ignitions and Wildland Fires in the Lower West Fork Analysis Area over the Last 

30 Years
Affected Environment & Environmental Consequences – Fire & Fuels

3.3-10 Lower West Fork Project Final EIS 

.

Figure 3.3-2: Fires per Year in 

the Lower West Fork Analysis

Area

Figure 3.3-3: Human and 

Lightning Caused Fires per 

Decade in the Lower West Fork

Analysis Area

Figure 3.3-4: Percent of 

Total Fires that are Human 

and Lightning Caused per 

Decade in the Lower West 

Fork Analysis Area

Total Lightning and Human Caused Fires per 

Decade in the Lower West Fork Area

0

10

20

30

40

50

1970 1980 1990 2000

Decade

Total Fires

Human

Lightning

Lightning/Human Fires 1970 - 2007

0%

20%

40%

60%

80%

100%

1970-1979 1980-1989 1990-1999 2000-2007

Decade

% of Total Fires

Lightning

Human

Wildland Fires per Year in Lower West 

Fork Analysis Area

0

2

4

6

8

10

12

14 1970

1974

1978

1982

198619901994

1998

2002

2006

Year

Number of Fires

# Fires/year

Mean Number

Fires/Year
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Project Final EIS 3.3-11

available initial attack resources within one hour of detection, the fire grew from a spot to well over ten 

acres. For the first couple of days the fire grew rapidly and exhibited active crown fire behavior. The fire 

was managed to protect at risk private property values in the West Fork drainage to allow the fire to 

continue burning to the east. This large fire adjacent to the WUI required forest area closures and 

evacuations of private residences and produced considerable smoke. Large fires typically cost millions of 

dollars to manage over several weeks. The total cost of the Rombo Fire was $7.2 million dollars. 

From the 1990s through the present, fire sizes on the Bitterroot NF have been growing due to increases in 

fuels, larger patch sizes, and changes in stand composition and structure. Removal of fire as a natural 

disturbance coupled with historic harvest practices (i.e. selective harvest of large, fire resistant trees, 

leaving less resistant trees), inadvertently reduced the likelihood of non-lethal fire, and effectively

increased the potential of high intensity, high severity fires in the Lower West Fork area. 

Fire type is used to describe current fire behavior conditions in the Lower West Fork analysis area. Fire 

type was modeled as described above under Analysis Methods. One weather scenario was used in all fire 

behavior modeling to simulate “Extreme” fire danger conditions that typically occur during the peak fire 

season on the Bitterroot National Forest. Modeling inputs included a maximum temperature of 88 degrees 

Fahrenheit, a 10-hour fuel moisture of 2%, and live fuel moisture of 75%, with three wind directions from 

the south, southwest, and west at 30 miles per hour (PF-FIRE-57). 

“Fire Type” describes whether the fire is a surface fire, an intermittent crown fire (also described as a 

torching fire), or a crown fire. A surface fire burns in the understory with relatively low flame lengths and

intensities and consumes litter, duff, and low-growing vegetation. A torching fire is a fire where flames 

move from the surface to consume single or small groups of overstory trees. Tree torching is determined 

by weather, total fuel load, live fuel moistures (for those fuel models that incorporate live fuels in addition 

to dead fuel) and ladder fuels (Andrews and Chase 1989). Torching fire behavior is of a higher intensity 

than surface fire, but is not sustained. A crown fire is one that becomes well-established in the overstory, 

moving from tree crown to tree crown at high intensities and high rates of spread while consuming surface 

fuel as well as overstory tree crowns. Crown fires are sometimes referred to as stand-replacing fires. 

Crown fire potential is increased by high wind speeds, low foliar moisture content, high surface fire 

intensity, presence of ladder fuels, sufficient canopy bulk density to sustain fire spread, and an unstable 

atmosphere (Van Wagner 1977, Rothermel 1991). Once a crown fire is established, it tends to affect large 

areas because it moves fast and is usually impossible to control until fuel or weather conditions change the 

fire behavior.

Fire Type: Existing Condition

Crown fires and torching trees are dangerous because they can loft hot firebrands that are carried long 

distances by prevailing winds. When firebrands land on receptive fuels, they have the potential to start 

“spot fires” ahead of the main fire. Spot fires severely limit the ability of firefighters to contain a fire. 

Spotting is determined by the source of the firebrands, how far they travel, and the probability of ignition 

upon landing (Rothermel 1983). Short-range spotting is not crucial because the main fire often overruns 

the spots and they contribute little to forward fire spread. Long-range spotting occurs when embers are 

lofted in the convection column of the fire and carried a mile or more in front of the main fire. They start 

new fires that burn independently of the main fire. Long-range spotting is hard to predict except that it is 

associated with high fire intensities, torching, crowning, and fire whirls (Rothermel 1983). Fires exhibiting 

long-range spotting pose some of the greatest threats to firefighter safety because they are extremely 

difficult to control and are less predictable. Reducing excessive surface fuel loads, ladder fuels, and crown 

bulk density by increasing crown spacing decreases the potential for extreme fire behavior. 

Surface fires are the more typical fire type in the low-elevation, dry forests of the Lower West Fork 

analysis area, and therefore, preferred to torching and crowning fires. Residents of the area favor lower 

intensity fire because high intensity fires threaten their safety, and reduce scenic quality by killing large 

tracts of forest. Torching fire behavior would be considered more acceptable than crown fires. 
Affected Environment & Environmental Consequences – Fire & Fuels

3.3-12 Lower West Fork Project Final EIS 

The most important changes to stand structure and composition in the Lower West Fork analysis area have 

been in small to medium-sized, shade tolerant conifers that are sensitive to fire. Higher densities of shade 

tolerant tree species in the understory lowers crown base heights and links surface fuels to crown fuels. 

These understory trees act as ladders that allow fire to burn into the overstory tree crowns. Stands in which 

fire has been excluded for long periods tend to be multi-storied and multi-aged with an abundance of shade 

tolerant species in the understory. Preheating of vegetation due to increased dead and down fuel loads 

allows fire to move from trees with low crown base heights into the multistoried crown causing the loss of 

larger overstory trees that have survived many low intensity fires prior to the increase in ladder fuel.

Increased stand density decreases crown spacing. The tighter the tree spacing, the easier it is for fire to 

move from crown to crown. Wind provides the mechanism for this behavior, so the tighter the tree crown 

spacing, the less wind it takes to move fire through the tree crowns under specific conditions. Therefore, 

even though wind speed may increase through a thinned forest, and the fire may move faster and exhibit 

higher surface fire intensity, the chance of a crown fire is diminished.

The potential fire type based on existing conditions was modeled using FlamMap and are displayed in 

Figure 3.3-5. Modeling the existing condition indicates 53 acres have potential for a torching fire and 

7,928 acres the potential for crown fire (Table 3.3-3).

Table 3.3-3: Area of Existing Fire Types Modeled with

a South, Southwest, and West Wind Scenario (Results 

were combined to determine area)

C. Wildland Urban Interface (WUI) - FMU-1 

The first priority in all wildland fire situations is to protect public and firefighter safety. Federal fire policy

direction for planning wildfire suppression strategies prioritizes the protection of life (both the public and 

firefighters) above private property and protecting natural resources (USDI/USDA et al. 1995). As fire 

moves across a landscape and toward or within the WUI, the hazards assumed by the public and firefighters 

increase with efforts to protect private property. The Bitterroot NF has some private property fire 

protection responsibilities in the WUI where Rural Fire Districts and Federal lands do not otherwise 

provide such protection. These areas are identified in an agreement with the State of Montana whereby the 

Bitterroot NF is the primary provider of rural fire protection on private lands, many of which include 

housing developments and other infrastructure. However, the Bitterroot NF has no authority to conduct 

fuel treatments or other wildland fire mitigations on these private lands.

The potential wildland fire exposure is high in the WUI and increases public and firefighter safety and 

property damage risks. The risks are increasing as more people move into the WUI and build expensive 

homes. The cost of fighting fire grows quickly as the risks increase and fuels build that support extreme 

fire behavior. For example, the 2006, 8,500 acre Gash Creek Fire outside of Victor, Montana, burned 

primarily in the WUI and cost in excess of 8 million dollars to control. Nearly the same amount of money 

was spent on the Rombo Fire even though the Rombo Fire was three times the acreage. The difference 

between the two fires was that the Rombo Fire burned largely outside of the WUI. Fuel treatments in the 

WUI reduce the potential of extreme fire behavior, decrease firefighter and public exposure to fire hazards, 

facilitate effective suppression and management, and move treated areas toward a more historic fire regime.

The WUI in the Lower West Fork analysis area is about 42 percent of the analysis area. The WUI accounts 

for approximately 15,832 acres, of which, approximately 3,339 acres is private property. There are 125 

Fire Type Area (acres)

0: No Fire (non-burnable) 7,280

1: Surface Fire 23,143

2: Torching Fire 53

3: Crown Fire 7,928
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Project Final EIS 3.3-13

Figure 3.3-5: Potential Fire Behavior Based on Existing Vegetation Conditions in the Lower West Fork 

Analysis Area
Affected Environment & Environmental Consequences – Fire & Fuels

3.3-14 Lower West Fork Project Final EIS 

individual private property listings on the Ravalli County tax records with homes or other improvements, 

for approximately 239 structures. 

“The urban wildland interface community exists where humans and their development meet or intermix 

with wildland fuel” (Federal Register, January 2001). The WUI boundary was delineated in the 

Community Wildfire Protection Plan (DNRC 2006, Appendix A p. 34). Fire specialists determined the 

WUI width in Lower West Fork on a site-specific basis that would protect values at risk from wildland fire

(PF-FIRE-043). The WUI boundary determines the level of response a fire start receives. It does not 

determine whether the area can or will be actively managed for fuels, or the strategies or tactics used to 

manage the fire. Every ignition in the WUI requires immediate attention due to the imminent risk to human 

properties or developments.

Local weather, fuel loads, topographic and ignition patterns, and the values at risk from wildland fire were 

evaluated when the Lower West Fork WUI was delineated. Any large fire (100 acres) or multiple ignitions 

in one day on the West Fork face have the potential to overwhelm suppression forces and travel unimpeded 

to the Forest Service/private land boundary. The 1994 Ward Mountain Fire, the Blodgett Fire in 2000, the 

Gash Creek Fire in 2006 demonstrated this scenario, as did the Rombo Mountain Fire in which values were 

at risk and several homeowners evacuated. The Little Blue Fire in 2000 started more than four miles from 

private property on a remote portion of the West Fork Ranger District, but became a WUI fire within 10 

hours (one burn period) causing home evacuations. The Wilderness and Roadless Area boundaries are

mid-slope in continuous fuels and there are few natural breaks to impede fires moving toward the West 

Fork River and adjacent developments. Lightning fires are often ignited on upper portions of the West 

Fork face, therefore the natural ridgeline and high elevation scree slopes do not provide natural barriers 

from unwanted wildland fires. These fires are also generally exposed to upper level westerly or southerly 

winds that when aligned with the continuous fuels increase the potential for a fire high on the face to move 

down or across slope toward the WUI at an accelerated rate. The topography in this area also favors 

downhill fire movement. Burning material rolls down the steep slopes and becomes aligned with the slope. 

The fire spread downhill by the burning material then burns back uphill (and uphill run) and increases the 

potential for large fire growth. 

3.3.4 ENVIRONMENTAL CONSEQUENCES

A. Direct and Indirect Effects

We evaluated the entire Lower West Fork analysis area in the effects analysis though only a portion of that 

total area is treated under the action alternatives.

Fire Type (Crown Fire Potential)

Alternative 1

The No-Action alternative does not change the potential fire types in the analysis area (Table 3.3-4). 

Figure 3.3-5 displays the FlamMap results relative to the proposed treatment areas. As forest structure 

becomes more homogeneous and fuel loads continue to increase, more land area would transition from 

surface to crown fire type.

Direct Effects

Table 3.3-4: Fire Type Area by Alternative in the Lower West Fork 

Project Area, Modeled with Uphill Wind Scenario 

Alternative Surface Fire Torching Crowning

1 23,143 53 7,928

2 24,066 47 6,598

3 23,622 47 7,042
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Project Final EIS 3.3-15

Fire management responses would continue to emphasize aggressive suppression to prevent fires moving 

onto private lands and to prevent the loss of large ponderosa pine trees that are susceptible to mortality due 

to ladder fuel development. 

Indirect Effects

Alternatives 2 and 3

Decreases in fire type categories are due to a reduction of surface, ladder, and canopy fuels. Additional 

reduction in Fire Type is expected outside of treatment areas because fires would be forced to either move 

through treatment zones as slower moving fires, or flank around treatment areas. However, the effect of 

treatments on fire behavior outside treatment zones was not modeled because it requires the temporally 

explicit FARSITE model (Finney 2004). Using FARSITE on the entire Lower West Fork analysis area

would be very difficult due to the number of variables required in the model to force it to burn across the 

whole area. The use of FARSITE is not necessary to compare the treatment effects between alternatives.

Table 3.3-4 shows the number of acres where Fire Type is changed.

Direct Effects 

Fuel reduction treatments decrease fire behavior by reducing fuel loads and increasing the space between 

tree crowns. Rates of surface fire spread may increase with treatment because the forest floor is more 

exposed to solar heating, wind passes more easily through the stand, and fine, herbaceous fuels proliferate 

under the more direct sunlight. However, the absence of ladder fuels prevents surface fires from being 

drawn into the tree crowns, which reduces the fire severity and fire type. 

Each action alternative reduces the area of potential crown fire behavior under extreme fire danger (overall 

reduced fire type). Alternative 2 has the largest reduction in fire behavior with a decrease of 1,330 acres of 

potential crown fire. Alternative 3 reduces the area of potential crown fire by 886 acres (3.3-6). 

Alternative 2 shows a greater decrease in the area of potential crown fire because more area is treated than 

under Alternative 3. Figures 3.3-7 and 3.3-8 provide a spatial representation of where potential fire 

behavior changes. 

Figure 3.3-6: Acres of Crown Fire by Alternative

Acres of Crown Fire Change by Alternative

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

Alternative 1 Alternative 2 Alternative 3

Acres

Before Treatment After Treatment
Affected Environment & Environmental Consequences – Fire & Fuels

3.3-16 Lower West Fork Project Final EIS 

Figure 3.3-7: Potential Fire Behavior in the Lower West Fork Analysis Area after Treatments under 

Alternative 2
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Project Final EIS 3.3-17

Figure 3.3-8: Potential Fire Behavior in the Lower West Fork Analysis Area after Treatments under 

Alternative 3
Affected Environment & Environmental Consequences – Fire & Fuels

3.3-18 Lower West Fork Project Final EIS 

More fire management options would be available besides aggressive fire suppression when responding to 

fire starts in the area. The decision space for managing fires would increase because the reduced fuel loads 

and ladder fuels, and the juxtaposition of treatment areas would reduce the potential fire behavior from 

crown fire to mostly surface fire (Table 3.3-4, Figure 3.3-6). In addition to the direct effects in treated

areas, there would be greater opportunity to use wildland fire in the adjacent wilderness and roadless areas 

because the fire would be easier to manage and control when it reaches the treated areas. This would allow 

fire to play a more natural role in resource management while balancing the risks to adjacent private lands 

and maintaining the visual quality people value. It would result in long-term benefits to the ecosystem and 

increase the options of using prescribed fire to maintain the fire adapted ecosystems in the future. 

Indirect Effects

B. Cumulative Effects

The cumulative effects analysis area encompasses the area north to the Trapper Creek watershed, south to 

Painted Rocks Lake, west to Nez Perce Pass, and east to the Sula Ranger District boundary. This area is 

larger than the analysis area, and was selected based on natural barriers and drainages. Effects of fuels 

reduction should not exceed these boundaries. Smoke issues due to prescribed burning in the effects 

analysis area are addressed in the Air Quality Section 3.4.

Analysis Area

Past, Current, Proposed, and Reasonably Foreseeable Activities

Cumulative Effects of the Alternatives

The existing condition reflects applicable past actions. All activities that have occurred in the cumulative 

effects analysis area for which effects are known are listed in Appendix B (Table of Past, Present, and 

Foreseeable Actions). All future timber harvests, mechanical fuels reductions, and prescribed burn

activities that are reasonably foreseeable in the cumulative effects area are also listed in Appendix B.

Past large-scale vegetative treatments could combine with this project to have a cumulative effect on fire 

and fuels resources. Finney (2000) found that overlapping treatments, which disrupted the heading and 

spread of a fire, decreased the size and intensity of the fire. Several timber harvests, mechanical fuels 

reductions, and prescribed burns have been completed in the cumulative effects analysis area over the past 

several decades (Fig. 3.3-9). Most however, affect relatively small areas relative to wildland fires and may 

not be large enough to disrupt fire spread. The spread of the 2006 Gash Creek Fire on the Stevensville 

Ranger District was effectively disrupted by the 2003 Big Creek Fire, which burned 1,125 acres, and a 

1999 whitebark pine prescribed fire that burned 140 acres. Also, the 1961 Sleeping Child Fire on the Sula 

Ranger District that burned 28,000 acres effectively disrupted the spread of the Valley Complex Fire in 

2000. Frazier Interface Fuels, School Point Ecoburn, and Trapper Bunkhouse are current and proposed fuel 

treatment and timber harvest projects within and adjacent to the Lower West Fork analysis area whose 

effects would combine with those of the Lower West Fork alternatives. The Frazier Interface Fuels project 

treated approximately 400 acres with commercial thinning, slashing non-commercial material, and 

prescribed burning. In School Point Ecoburn, slashing non-commercial material and prescribed burning

will treat 2,200 acres. In Trapper Bunkhouse a combination of commercial and noncommercial treatments,

including prescribed burning will occur on 5,827 acres. These treatments would combine with the effects 

of Alternatives 2 or 3 to create a largely contiguous buffer and decrease potential wildfire behavior in the 

WUI on the west side of the West Fork River. Under Alternative 1, the treatments would remain disjunct 

and the potential wildfire behavior in the WUI would remain high. On the east side of the West Fork 

River, stand treatments under Alternative 2 would combine with the effects of past wildfires to reduce 

potential fire behavior on the lower section of East Piquett Creek and at the private land boundary between 

Piquett and Violet Creeks. Treatment areas are non-existent or too small under Alternatives 1 and 3, 

respectively, to cumulatively affect potential fire behavior on the east side of West Fork River.

Timber Harvest and Fuel Reduction
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Final EIS 3.3-19 Figure 3.3-9: Fires, Timber Harvest, and Fuel Treatments in the Lower West Fork Cumulative Effects Analysis Area 
Affected Environment & Environmental Consequences – Fire & Fuels

Lower West Fork Final EIS 3.3-21

No resource benefit fires have occurred in the Lower West Fork analysis area although several incidents 

have occurred just outside of the analysis area in the Selway-Bitterroot Wilderness Area. The 2006 Lake of 

the Rocks Fire occurred in Boulder Creek drainage and burned to within 1⁄4 mile of Boulder Falls. 

However, wildland fire, prescribed fire, timber harvest, and plantations have positively contributed to the 

portion of the landscape in early seral development and open canopy stands.

The effects harvest activities have on fire behavior depend on the location and type of treatment. 

Strategically placed harvest activities or those that modify ground, surface, or aerial fuels can reduce 

potential fire behavior from crown to surface fire. Increasing the distance between tree crowns and treating 

the logging slash after timber harvest reduces fire spread and intensity and prevents flames from reaching 

into the tree crowns. If excessive logging slash is not reduced after harvest, it can compound fire behavior 

and increase the potential a fire would transition from surface fire to crown fire. 

Alternatives 2 and 3 would reduce potential fire behavior before the fire reaches private land on the west 

side of the West Fork River. The availability of Rural Conservation and Development funds may increase 

the amount of fuels treatment on private land. Fuel treatments and appropriate slash treatments on private 

land would combine with those on National Forest and further reduce potential fire behavior on both 

private and National Forest lands. If logging slash is not treated, the treatment benefits would be negated 

because the excess slash would intensify fire behavior through the treatment area. Limited fuels reduction 

treatments have occurred on private property within the Lower West Fork analysis area. Triple Creek 

Ranch has reduced fuels on their property over the last several years along with several other landowners. 

These activities, especially those adjacent to treatment units, extend the area of reduced fire behavior.

Travel management is an important issue to wildland fire suppression. Access directly affects response 

times for wildland firefighters and the types of equipment that can access wildland fire situations. This is 

vitally important in WUI areas where containment of fires is necessary to protect private property, 

structures, and the public from becoming involved in wildland fire situations. The longer it takes fire 

personnel to access a fire, the more resources will be needed to extinguish the fire. Length of response time 

may also determine whether the fire will become a long-term project fire. Wildland fire suppression 

success is due in part to quick response to ignitions.

Travel Management

Road decommissioning and storage is proposed under Alternatives 2 and 3. In Alternative 2, 9.9 miles of 

roads would be decommissioned and 18.7 miles would be stored. Alternative 3 proposes to decommission 

23.4 miles and place 18.7 miles in storage. The removal of these roads will have little or no effect on 

wildfire management access, and will not compromise the safety or efficiency of wildland fire personnel 

during fire management operations because these areas are still adequately roaded. The main road access 

would be maintained in the same areas where roads would be decommissioned. Road densities decrease in 

three 3rd order watersheds, 02e424-1, 02e424-2, and 02f427-3 (FEIS pg. 3.8-15. Road density is reduced 

the most in 02f427-3 by 1⁄2 mile per square mile and the least in 02e424-1 by one-tenth mile per square 

mile. 

Off-highway vehicle (OHV) use is low in the analysis area. However, there is slight potential that

recreational vehicles could start fires on the more primitive designated roads and trails. Vehicles without 

spark arresters or heat shields could ignite fires when driving through tall grass or light flashy fuels. 

Getting debris caught in the undercarriage, brake problems, dragging chains, or the vehicle itself catching

fire are other ways vehicles could start fires. There are no areas designated for cross-country travel in the 

Lower West Fork analysis area; OHV use is confined to roads, and trails. Off-highway vehicles can access 

further into the Forest, which could potentially increase the extent of wildland fire ignitions. OHV use is 

highest during the time of year when fuels are the most flammable; however, when fire potential is 

extreme, the National Forest is closed to public use in order to prevent ignitions.

Recreation
Affected Environment & Environmental Consequences – Fire & Fuels

3.3-22 Lower West Fork Project Final EIS 

The use of prescribed fire following timber harvest and fuels reduction activities reduces potential fire 

behavior and severity. The use of fire reduces duff, litter, and dead and down woody material that has 

accumulated after years of fire exclusion, and reduces activity fuels. The use of fire restores and maintains

fire-adapted ecosystems and reduces the potential of high-intensity wildfire and overstory mortality. 

Prescribed Fire 

3.3.5 CONSISTENCY WITH FOREST PLAN, LAWS, AND REGULATIONS

All alternatives in the Lower West Fork Project are consistent with hazardous fuel reduction, rehabilitation, 

and restoration in the National Fire Plan. The project responds to the objectives and standards outlined in 

the Bitterroot NF Forest Plan and the Bitterroot Fire Management Plan for management areas (MA-1, 2, 

3A, 3C, 5, 6, 8a and 9) and fire management units (FMU-1, 2, and 3). Coarse woody debris requirements 

in some areas exceed the parameters set forth in the Forest Plan but are within the Forest Plan amendment

parameters identified in Chapter 1. The project is responsive to the objectives in the Bitterroot Fire 

Management Plan by integrating fire and fuels management options into an interdisciplinary project 

designed to move the Lower West Fork Area towards desired conditions.

This project is consistent with the Healthy Forests Restoration Act of 2003 (HFRA), which requires federal 

land managers address hazardous fuels and FRCC class 2 and 3 vegetation in high priority areas as 

identified by the Bitterroot Community Wildfire Protection Plan (Bitterroot Resource Conservation and 

Development, 2006). However, this project is not being completed under the HFRAs expedited planning 

process because additional purpose and needs were identified for inclusion in the NEPA analysis.
Affected Environment & Environmental Consequences – Air Quality

Lower West Fork Project Final EIS 3.4 - 1

3.4 AIR QUALITY

3.4.1 SCOPE OF ANALYSIS AND ANALYSIS METHODS

A. Area of Analysis

The Lower West Fork Project Area is in Montana/Idaho Airshed 4, which includes the Bitterroot National 

Forest and the western boundary of the Selway-Bitterroot Wilderness, and all of Ravalli County. The 

airshed boundary is identical to Ravalli County boundaries and is the analysis area of direct and indirect 

effects on air quality. The Montana/Idaho Airshed Group (Airshed Group), authorized by the Montana 

Department of Environmental Quality (MDEQ), defines and manages the airsheds. The Airshed Group 

implements the Smoke Management Program in Montana and Idaho using Best Available Control 

Technology (BACT). More information about this group and managing the competing needs of restoring 

fire to fire adapted ecosystems while maintaining clean air and protecting public health can be found at, 

http://www.smokemu.org. The 1.35 million acre Selway-Bitterroot Wilderness is a Class 1 Airshed located 

directly west of the Selway-Bitterroot roadless area. Missoula and Butte, Montana are the closest impact 

zones and are non-attainment areas. Smoke from the proposed treatments would not affect the impact 

zones because it would disperse before reaching them. The impact zones are not included in the analysis 

area.

Figure 3.4-1: Lower West Fork Airshed and Impact Zones

Air quality terminologies used in this analysis are defined as follows.

Ø “Attainment Areas” are areas that have not exceeded the National Ambient Air Quality 

Standards (NAAQS) for certain criteria pollutants. NAAQS exist for ozone, carbon monoxide, 

sulfur dioxides, nitrogen dioxide, lead, and fine (PM 0-2.5) and coarse (PM2.5-10) particulate 

matter.
Affected Environment & Environmental Consequences – Air Quality

3.4- 2 Lower West Fork Project Final EIS 

• "Non-attainment Areas" are areas that have exceeded the NAAQS for certain criteria 

pollutants. 

Ø "Class I Area" is the Clean Air Act (CAA) classification that protects the air quality in 

international parks, national parks greater than 6,000 acres, and national wilderness areas greater 

than 5,000 acres that existed on August 7, 1977.

Ø “Criteria Pollutants” are six common pollutants that the Environmental Protection Agency 

(EPA) uses to determine the air quality designation. The six pollutants are ozone, carbon 

monoxide, nitrogen dioxide, particulate matter, sulfur dioxide, and lead.

Ø “Fine particles” are airborne particles less than 2.5 micrometers in diameter (PM2.5)

Ø "Impact Zone" means any area of Montana or Idaho that the Airshed Group or a local program 

identifies as smoke sensitive and/or having an existing air quality problem. Impact Zones exist 

in Montana and Idaho.

B. Analysis Methods

This section describes the methods used to analyze air quality. The two main issues related to air quality 

are:

Ø Smoke emissions from understory and pile burning associated with the Lower West Fork

project may adversely affect residents in the Conner and Darby area.

Ø Smoke emissions from understory and pile burning associated with the Lower West Fork

project could adversely affect the Selway-Bitterroot Wilderness Class 1 Airshed.

The analysis identifies treatment units and type of burn treatment for each unit. Total treatment area is

calculated by alternative. 

Measurement indicators are estimations for:

Ø 24-hour maximum downwind smoke emissions measured as fine particles, PM2.5 micrograms 

per cubic meter (ug/m3).

Ø Effect on the Class 1 Airshed as measured in upwind concentrations of PM2.5 (ug/m3).

Particulate matter is the main pollutant for which prescribed fire emissions are monitored, PM2.5 and 

PM10 (EPA Website; www.epa.gov/pmdesignations). Fine particles (PM2.5) can lodge deeply into the 

lungs because of their small size, approximately 1/30th the average width of a human hair (EPA Website; 

www.epa.gov/pmdesignations). They have been associated with premature mortality and other serious 

health effects. Sources of fine particles include all types of combustion activities (motor vehicles, power 

plants, wood burning, etc.) and certain industrial processes. 

Pollutants

Particles less than 10 micrometers in diameter (PM10) pose a health risk because they can be inhaled and 

accumulate in the respiratory system. "Coarse” particles have diameters between 2.5 and 10 micrometers. 

Sources of coarse particles include crushing or grinding operations, and dust from paved or unpaved roads. 

Other particles may be formed in the air from the chemical change of gases when gases from burning fuels 

react with sunlight and water vapor. These particles come from fuel combustion in motor vehicles, at 

power plants, and in other industrial processes (Environmental Protection Agency Website; 

www.epa.gov/pmdesignations).

The PM2.5 level will have the most significant impact on the area and people surrounding the project area,

and is the focus of the assessment. 

Description

Smoke Impact Spreadsheet (SIS)

The Smoke Impact Spreadsheet (SIS) is a planning model that estimates particulate matter (PM) emissions 

and concentrations downwind of wildland fires (Air Sciences 2003). SIS conservatively predicts (estimates 
Affected Environment & Environmental Consequences – Air Quality

Lower West Fork Project Final EIS 3.4 - 3

higher than actual) downwind PM concentrations for comparison with appropriate Federal or State air 

quality standards. Embedded in SIS is an emissions module that calculates broadcast burn and wildfire 

emissions using the First Order Fire Effects Model (FOFEM 5.0, Reinhardt et al. 1997) and pile burning 

emissions using the CONSUME 2.1 (Prichard et al. no date) pile wizard. The SIS also incorporates the 

CALPUFF dispersion model that calculates downwind concentrations.

Primary Use in Analysis

SIS was used to assess the longevity of exposure to PM2.5 concentrations over time due to prescribed 

burning activities and to determine the potential to exceed EPA and the MDEQ PM2.5 standards set by the 

CAA and NAAQS.

The process used to determine the burn input spreadsheet was:

1. Identify all units being treated with prescribed fire in the alternatives

2. Identify the associated National Fire Danger Rating System (NFDRS) fuel models 

corresponding to fuels within each unit 

3. Determine associated fuels treatment based upon proposed silvicultural treatments (e.g. pile 

burn, broadcast burn, slashing treatment)

4. Determine aspect and elevation

5. Determine treatment size (acres)

6. Identify the major overstory tree species in each unit

Inputs for the SIS model were identified and the list was sorted by NFDRS fuel models, treatment and 

forest cover types, and elevation. Unique combinations were grouped for modeling. After grouping like 

units together a descriptive scenario code was assigned to the groups corresponding to the SIS modeling 

inputs. One run was performed for the largest area in each group, which accounted for the largest potential 

smoke output for each modeling group. The modeling variables, for example time of year, strip spacing, 

time between pile ignitions, were determined for each grouping based on the fuels specialists’ experience 

with modeling, fire behavior, and prescribed fire. 

Core Assumptions

The SIS model predicts 1-hour and 24-hour average PM2.5 concentrations, estimates the effects of daytime 

and nighttime meteorological conditions, and incorporates a simplified terrain profile.

Known Limitations

SIS is a prescribed fire planning tool, not an operational tool. It assists land managers make informed 

decisions using the best available science. SIS models the interactions of fire variables and estimates the 

relative changes in air quality. It does not consider use of actual weather records or three-dimensional 

terrain data but does include:

Ø For pile burns – pile shape, dimensions, packing ratio, fuel type for pile burns, and number of piles 

per burning period.

Ø For broadcast burns – subunits, starting hour, strip width, strip length, number of strips, strip 

spacing, ignition rate (ft/min), and ignition time (hours).

Ø For meteorology – burn date, latitude, 10-meter wind speed (mph), wind direction offset (degrees), 

maximum temperature, Pasquill-Gifford stability class.

Ø For terrain – maximum distance, average elevation of burn, terrain profile.

Because SIS is not an operational tool, it is not used to make the “go/no-go” decisions to ignite prescribed 

fires.

Anticipated Consequences of Limitations

The SIS model provides worst case scenarios of smoke impacts from the proposed prescribed fire

treatments based on the time of year treatments are most likely to occur. Model inputs are constants and 
Affected Environment & Environmental Consequences – Air Quality

3.4- 4 Lower West Fork Project Final EIS 

there is no avenue to incorporate variability due to landscape, weather, or human factors. The model will 

not precisely determine the exact amount of smoke release from a burned unit. The possibility of higher

smoke production, duration of smoke released, or smoke retention from a burned unit exists because the 

fire may burn longer than one day; conditions may be warmer, drier, or windier than expected; unpredicted 

stable air masses may settle over the burn area; or fires may burn past control features or unit boundaries. 

Weather and air masses are not always accurately predicted for each burn. This tool is not a precise 

prediction of particulates; however, it is an appropriate tool for analyzing and comparing the potential 

effects between different alternatives. 

3.4.2 REGULATORY FRAMEWORK

A. National Guidance

Congress passed the CAA in 1970, and amended it in 1977 and 1990. The purpose of the CAA is to protect 

and enhance air quality while ensuring the protection of public health and welfare. The act established 

NAAQS (Table 3.4-1), which must be met by most state and federal agencies, including the Forest Service.

Clean Air Act (CAA)

Table 3.4-1: National Ambient Air Quality Standards for Particle Pollution Set by the Clean Air Act

(see the complete table of National Ambient Air Quality Standards at http://www.epa.gov/air/criteria.html)

Units of measure for the standards are micrograms per cubic meter of air (μg/m3).

Footnotes: 1 - Not to be exceeded more than once per year on average over 3 years. 2 - To attain this standard, the 3-year average of the weighted annual mean PM2.5 concentrations from single or 

multiple community-oriented monitors must not exceed 15.0 μg/m3. 3

- To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each 

population-oriented monitor within an area must not exceed 35 μg/m3 (effective December 17, 2006).

States are given the primary responsibility for air quality management. The CAA requires states to develop 

implementation plans that identify how the state will attain and maintain NAAQS. The Montana CAA 

promulgated the state implementation plans and created the Montana Air Quality Bureau (now under the 

Department of Environmental Quality). The CAA also allows States, and some counties, to adopt unique 

permitting procedures and to apply standards that are more stringent. MDEQ has authorized the 

Idaho/Montana Airshed Group (made up of State and Federal resource management agencies and private 

companies with a history of prescribed fire use) to regulate smoke emissions through a burn approval 

process and monitoring program (www.smokemu.org). The CAA requires that Forest Service actions have 

“no adverse effect” on air resources by meeting the NAAQS and non-degradation standards for Class I 

Areas, such as the Selway-Bitterroot Wilderness Area. Managers are further directed to improve 

substandard existing conditions and reverse negative trends where feasible. Missoula and Butte are “nonattainment” zones in need of improvement; however, they are outside the impact area of this project. 

All prescribed fire burn plans will address mitigation measures to minimize smoke impacts and comply 

with the CAA. The Lower West Fork project is designed to meet the goals, objectives and standards set 

forth in this law and the following local regulatory framework.

National Ambient Air Quality Standards for Particle Pollution

Pollutant Primary Standards Averaging Times Secondary Standards

Particulate Matter 

(PM10) 150 μg/m3 24-hour 1

Particulate Matter 

(PM2.5)

15.0 μg/m3 Annual 2 (Arith. Mean) Same as Primary

35 μg/m3 24-hour 3
Affected Environment & Environmental Consequences – Air Quality

Lower West Fork Project Final EIS 3.4 - 5

B. State Guidance

The MDEQ oversees the airshed programs the Montana and Idaho Airshed Group (Airshed Group) 

implements. All prescribed fire proposed in Montana is reviewed and coordinated through the Airshed 

Group, which accepts or rejects prescribed fires based on numbers of proposed prescribed fires and local 

weather forecasts. The annual MDEQ smoke permit requires agencies responsible for the prescribed fire 

(burners) to implement BACT. BACT are techniques and methods of controlling pollution emissions from 

an existing or proposed open burning source to the maximum degree. MDEQ determines, on a case-bycase basis, what controls are achievable for that source. MDEQ takes into account impacts on energy use, 

the environment, the economy, and any other costs, including the cost to the source.

Department of Environmental Quality and Montana and Idaho Airshed Group

Such techniques and methods may include the following:

Ø Scheduling burning during periods and seasons of good ventilation

Ø Forecasting smoke dispersion

Ø Using MDEQ models to predict and minimize smoke impacts

Ø Limiting the amount of burning at any one time

Ø Using ignition and burning techniques which minimize smoke production

Ø Preparing fuels to minimize dirt and moisture content

Ø Configuring fuels to create adequate air-to-fuel ratio

Ø Prioritizing burns as to air quality impact and assigning control techniques accordingly

Ø Promoting alternative treatments and uses of materials to be burned

Ø Selecting sites that minimize smoke impact.

C. Local Guidance

Direction provided in the Forest Plan (1987, pg. II-6) includes Forest-Wide Management Direction 

Bitterroot Forest Plan and Fire Management Action Plan

Ø Cooperate with State Air Quality Bureaus to prevent significant deterioration of air quality.

Forest-wide Management Standards (Forest Plan pg. II-25) include: 

Ø The Forest will cooperate with the Montana and Idaho Air Quality Bureaus in the State 

Implementation Plans. The Bitterroot National Forest is an active member of the Montana State 

Airshed Group and adheres to practices and policies of the State of Montana Cooperative Smoke 

Management Plan.

The 2009 Bitterroot National Forest Fire Management Plan references the Montana/Idaho Airshed Group 

guidance on making “go/no-go” ignition decisions as direction to burners for prescribed fires on the 

Bitterroot National Forest. This plan is updated annually.

3.4.3 AFFECTED ENVIRONMENT

A. Air Quality

Air quality in the Lower West Fork project area is generally excellent, with limited local emission sources 

and consistent wind dispersion during much of the year. Existing sources of emissions around Darby and 

in the West Fork of the Bitterroot River drainage include residential wood burning, debris burning, road 

dust, light industry, vehicles, construction equipment, and wildland fire. Emissions are low much of the 

year, with winter being the period with the greatest emissions from residential wood burning for heat. 

Wildland fires can produce substantial emissions in the summer and fall for short to moderate durations. 

Occasional inversions develop in the winter during winter burning periods with stable atmospheres. 
Affected Environment & Environmental Consequences – Air Quality

3.4- 6 Lower West Fork Project Final EIS 

However, the north-south orientation of the Bitterroot Valley coupled with the typical south-west to northeast weather patterns allows good smoke dispersal most of the time. 

The proposed prescribed fires are not subject to conformity provisions of the CAA because the project area 

is outside the “non-attainment” areas. The conformity provisions prohibit federal agencies from taking any 

action that contributes to a new violation of the standards, increases an existing violation, or delays 

attainment of a standard within a non-attainment area. The Lower West Fork project is not subject to the 

conformity provisions since it does not occur within a non-attainment area boundary. The Lower West 

Fork Project Area lies entirely within Montana Airshed 4. The airshed is considered an attainment area by 

the MDEQ. Both the Missoula and Butte non-attainment airsheds are outside the area of influence for 

prescribed fires in the analysis area. 

The Class 1 Airshed is located upwind and a quarter mile, at the closest, from the project area. The eastern 

edge of the wilderness could be affected by the proposed project during periods of atmospheric stability or 

post-burning. Class I areas must have a Prevention of Significant Deterioration (PSD) permit for new 

stationary sources. A stationary source is a source of pollution that is well-defined, such as a smokestack. 

The Lower West Fork project is not considered a major stationary source and therefore is not subject to the 

PSD permitting requirement.

The IMPROVE visibility program (Interagency Monitoring of Protected Visual Environments) is a 

cooperative measurement effort designed to:

IMPROVE Sites

Ø establish current background aerosol concentrations in mandatory Class I areas

Ø identify chemical species and emission sources responsible for existing man-made visibility 

impairment

Ø document long-term trends

Ø provide regional haze monitoring when obtainable at mandatory Class I areas (Crocker 

Nuclear Laboratory 1999)

The nearest particulate data comes from Sula Peak IMPROVE site located 12-20 miles east-southeast of the 

project area. The IMPROVE site monitors particulate matter and visibility for both the Anaconda-Pintler 

Wilderness and the Selway-Bitterroot Wilderness. The following photos (Figs. 3.4-2, 3.4-3) are visibility 

readings looking back into the Lower West Fork project area and into the Selway-Bitterroot Wilderness. 

Data from 1994 to 2006 show annual ranges of PM2.5 on a 24-hour basis, ranging from 0.03 ug/m3 to 52.8 

ug/m3

. The maximum value was recorded at the end of August in 2000 when wildfires were burning 

around much of the Bitterroot Valley. The Sula Peak IMPROVE site was offline for much of the fire 

season in 2000 and did not sample air quality during the peak of the wildfire activity. Figure 3.4-4 shows 

minimum and maximum particulate levels over the last 12 years collected from the IMPROVE site on Sula 

Peak (IMPROVE data available at: http://vista.cira.colostate.edu/). 

3.4.4 ENVIRONMENTAL CONSEQUENCES

A. Direct and Indirect Effects

The link between hospital admissions for respiratory and circulatory diseases and smoke exposure is 

ambiguous (Sharkey 2001). The Centers for Disease Control and Prevention (CDC) investigated whether 

respiratory and cardiovascular hospital admissions increased in four Montana counties during forest fires of 

2000. The study compared differences in hospital admissions between 1999, when wildfires were few, and 

2000, when there were many. The counties in the study were Ravalli, Missoula, Lewis and Clark, and 

Yellowstone. Based on hourly PM10 levels, Ravalli County had the highest exposure to smoke and 

Yellowstone County had the lowest. Missoula and Lewis and Clark Counties both had moderate 

Smoke Exposure and Hospital Admissions
Affected Environment & Environmental Consequences – Air Quality

Lower West Fork Project Final EIS 3.4 - 7

exposures. Respiratory disease (chronic obstructive pulmonary disease and pneumonia) and circulatory 

disease admissions were evaluated.

Figure 3.4-2: Sula Peak Visibility 18-24 Miles Figure 3.4-3: Sula Peak Visibility 186 – 210 Miles

Note: There were several samples taken during 2006 where the sample clock was 12 hours 

off the correct time. This does not impact the maxima and minima values presented here. 

For the purposes of this discussion, the 2006 data is valid. (Personal Communication, 

Thomas Dzomba, 2008) 

Figure 3.4-4: Maximum annual 24-hour PM2.5 Level from 1994 – 2006
Affected Environment & Environmental Consequences – Air Quality

3.4- 8 Lower West Fork Project Final EIS 

Particulate levels were higher during the 12-week period in 2000 than in 1999; mean PM10 levels in 

Ravalli County were 47 ug/m3, and 34.2 ug/m3 in Lewis and Clark County. Hospital admission rates for 

the period (July, August, and September) increased in 2000 for respiratory and circulatory problems, and 

the admissions rates were higher in the high exposure area. However, analyzing the data on a month by 

month basis, a temporal exposure-response relationship between particulate levels and rates of hospital 

admission for respiratory and circulatory problems occurred in July, before the high smoke exposures of 

August. Missoula County had fewer admissions for circulatory causes in August, while Yellowstone 

County, the low exposure area, showed an increase. More detailed studies are needed to determine whether 

there is a link between hospital admissions and smoke exposure.

All alternatives have the potential to produce smoke from wildland fires. Wildland fires will continue to 

burn and produce smoke, primarily during the summer months. Brown et al. (2001) state that the risk of 

severe fire after the fires of 2000 is relatively low within 10 years of the fire, moderate within 10 to 30 

years of the fire, and high within 30 to 60 years of the fire. 

Effects Common to All Alternatives

Alternative 1

No smoke would be produced by management ignitions under Alternative 1, the No Action alternative. 

However, Alternative 1 would not reduce current heavy fuel loadings and fuel continuity on the Lower 

West Fork project area. For this reason, it is the least effective of the three alternatives in reducing 

potential smoke emissions and associated pollutants from future wildland fires. 

In the absence of fuel reduction, and in the event of future wildland fire, varying levels of smoke could 

persist in the Bitterroot Valley for several weeks. Health and visibility could be adversely affected 

depending on local climatic conditions, level of smoke dispersion, and amount of smoke the fire produces. 

Alternatives 2 and 3

Alternatives 2 and 3 would effectively reduce potential smoke emissions and associated pollutants in the 

long term. Alternative 2 will do the most to improve potential smoke impacts because more fuels would be 

thinned and burned in areas that have high crown fire potential. Also, more areas would have fires 

periodically prescribed following treatment, which would keep fuel loads down for the long term.

In Alternatives 2 and 3, excess slash produced by treatment activities would be underburned in all units 

except plantation thinnings, and some areas would be piled and burned. Smoke emissions vary with 

combustion efficiency and quantity of fuel burned. Machine piles and hand piles (jackpot burns) tend to 

produce more smoke than other burns because much of the consumption occurs during the inefficient 

smoldering phase of combustion. Underburns tend to produce less smoke than jackpot burns because less 

fuel is available to burn. 

Table 3.4-2 shows the modeled maximum PM2.5 concentrations emitted from proposed prescribed fire 

activity. The 24-hour maximum PM2.5 value would be below the 35 μg/m3 threshold within 0.1 mile 

downwind of the burn. For all runs, the PM2.5 concentrations drop off rapidly after 0.1 mile and never

exceed the threshold (Fig. 3.4-5, 3.4-6). The Forest Service will use BACT when these units are burned to 

mitigate potential smoke impacts as described in Section 3.4.2. Generally, impacts would be minimal and 

confined to the project area. However, though prescribed fires are scheduled to occur during favorable 

weather forecasts, unpredicted weather changes can keep smoke from dispersing as intended.

The east boundary of the Selway-Bitterroot Wilderness is located within a quarter mile of some proposed 

prescribed fires. Wilderness visitors may observe smoke from the project area but it would not be likely to 

affect them. Burning is planned and implemented for days when winds and atmospheric instability are 

expected to dissipate smoke away from the wilderness area during the day. At night, down slope and down 

valley winds will take the smoke directly away from the wilderness area. Visitation to the wilderness area 

is low during spring when most broadcast burns are ignited. Fall burns include one broadcast burn and pile 

burn of short duration. 
Affected Environment & Environmental Consequences – Air Quality

Lower West Fork Project Final EIS 3.4 - 9

Table 3.4-2: Maximum Downwind Concentrations of PM2.5 (ug/m3) for Each Modeling Scenario Used 

in the Smoke Impacts Spreadsheet (SIS) and Mitigations and Considerations

Run/ 

Modeling 

Group 

Code1

LWF

Unit#

Modeled

Modeled 

Unit Acres

Total 

Acres 

Treated 

Alt 2

Total 

Acres 

Treated 

Alt 3

Cover

Type

Mitigations and 

Considerations*

24-hr max 

PM2.5

(μg/m3) 0.1 mi 

downwind 

from unit 

(with 

mitigations)

cub4pp 61 418 596 448 Ponderosa Pine None 10.7

cub5pp 64 246 681 146 Ponderosa Pine None 13.1

gub4pp 13 84 116 0 Ponderosa Pine None 7.1

gub5pp 18 36 68 33 Ponderosa Pine None 5.1

hub4pp 9 109 160 109 Ponderosa Pine None 11.3

hub5pp 33 282 1,720 1,439 Ponderosa Pine None 15.2

hub6pp 24 19 41 0 Ponderosa Pine None 4.2

hub5mc 61A 415 721 676 Mixed Conifer None 20.4

hub6mc 60 134 295 162 Mixed Conifer None 16.1

cpb5pp 87 38 60 60 Ponderosa Pine None 0.6

cpb6pp 92 27 73 73 Ponderosa Pine None 1.0

fpb6mc 91 28 28 28 Mixed Conifer None 0.2

gpb5pp 95 43 167 167 Ponderosa Pine None 0.2

hpb5pp 89 61 176 176 Ponderosa Pine None 0.3

hpb6pp 80 24 65 65 Ponderosa Pine None 0.3 1

Modeling group code begins with NFDRS Fuel Model designation (C, G, H) followed by pile burn (pb) or underburn (ub) 

designation, elevation code x1000 (e.g. “5” is 5000 feet), and cover type abbreviation (pp=ponderosa pine, mc=mixed 

conifer). 

NFDRS Fuel Models: Fuel Model C = Open Pine w/ Grass: Fuel Model G = Short Needle Litter, Closed Canopy, Heavy 

Dead; Fuel Model H = Short Needle Litter, Closed Canopy, Normal Dead. (Deeming et al. 1977).

Typical spring conditions are represented by May 15, 10 mph 20-foot windspeed, maximum temperature of 75 degrees F, 30% 

moisture content for 1000-hour fuels, and 75% moisture content for duff.

Typical fall conditions are represented by September 15, 10 mph 20-foot windspeed, maximum temperature of 75 degrees F, 

20% moisture content for 1000-hour fuels, and 100% moisture content for duff.

Daily particulate matter standards would be met in Alternatives 2 and 3 by following the Montana/Idaho 

Smoke Management Plan. That is, NAAQS for PM2.5 and PM10 would be met by implementing BACT, 

which may include limiting the area burned on any particular day. Smoke from prescribed burning would 

cause short-term impacts on recreation and transportation in and near the project area. The size and 

location of a prescribed burn and weather conditions (e.g. temperature, wind, atmospheric stability and 

mixing, and fuel moisture) determine how much and in what direction smoke travels. Residents in or near 

the mouths of drainages might experience short-term periods of smoke during early morning inversions.

The effects of each alternative differ in the area treated and in the quantity of smoke that would be 

produced. Table 3.4-3 shows the emissions produced, tons of PM2.5 and PM10, for each alternative 

depending on the type and quantity of fuel treatments. Model scenarios were used to estimate particulate 

matter emission for the type of burn, summing the total area for that type of treatment, then multiplying the 

tons/acre by acres represented in that modeling scenario. The initial treatments would take up to six years 

to complete, and the post-treatment burns would occur 6-10 years after the initial treatments, therefore the 

particulate production shown in Table 3.4-3 would be dispersed over the next 15 years. The alternatives 

also differ in the area treated per ton of PM2.5 produced. Under Alternative 2, 4.0 acres would be treated 

for every ton of PM2.5 produced compared to 3.5 acres treated for every ton of PM2.5 produced under 

Alternative 3. 
Affected Environment & Environmental Consequences – Air Quality

3.4- 10 Lower West Fork Project Final EIS 

Figure 3.4-5: 24-Hour Maximum PM2.5 Concentrations Modeled by the Smoke Impact Spreadsheet 

(SIS) Program. Initial concentrations closest to the burn unit are highest, dropping significantly with 

increased downwind distance from the unit. These modeling scenarios represent each underburn units

in Alternatives 2 and 3 corresponding with scenarios in Table 3.4-2

The heavy fuel loadings and the resulting emissions in the action alternatives are more than the regional 

averages for upper Clark Fork and central Idaho described by Ottmar et al. (1996) and Brown et al. (2001). 

Ottmar et al. (1996) calculated the average fuel loadings in the upper Clark Fork near 19 tons per acre, 

which approximates the average fuel loads in the alternatives. The estimated emissions of the action 

alternatives are nearly two to six times below wildland fire emissions (Ottmar et al. 1996). Ottmar et al. 

(1996) indicated wildland fires produce two – four times as much particulates as prescribed fire because 

wildland fires generally burn during drought period and consume more total fuel.

Prescribed Fire Emissions Compared to Wildland Fire Emissions

All fires have the potential to temporarily affect downwind visibility.

The SIS with embedded models CONSUME 2.1 and FOFEM5 were used to model smoke concentrations 

while CALPUFF modeled dispersion rates of smoke after burning. Downwind PM2.5 particulate 

concentrations are less than 20.4 ug/m3 in all cases (Table 3.4-2); low particulate matter concentrations 

imply visibility and health would be minimally affected.

Concentrations

24 hour Maximum PM 2.5 Concentrations (Underburn)

0

5

10

15

20

25

30

35

40

0.10.30.50.70.91.11.31.51.71.9

Downwind Distance (Miles)

PM 2.5 Concentrations 

(Micrograms/cubic meter)

CBB4PP CBB5PP

GBB4PP GBB5PP

HBB4PP HBB5PP

HBB6PP HBB5MC

HBB6MC PM 2.5 Standard (ug/m3)
Affected Environment & Environmental Consequences – Air Quality

Lower West Fork Project Final EIS 3.4 - 11

Figure 3.4-6: 24-Hour Maximum PM2.5 Concentrations Modeled by the Smoke Impact Spreadsheet 

(SIS) Program. Initial concentrations closest to the burn unit are highest, dropping significantly with 

increased downwind distance from the unit. These modeling scenarios represent each underburn units

in Alternatives 2 and 3 corresponding with scenarios in Table 3.4-2.

B. Cumulative Effects

The cumulative effects area is Airshed 4.

Smoke from wildland fires would occur with all alternatives, the amount dependent upon climate. 

Wildland fires locally, or anywhere in the northwest and Canada, can affect regional haze in the Bitterroot 

Valley. Frequently, smoke produced from wildland fires on the Payette and Nez Perce National Forests 

carries into the Bitterroot Valley. This smoke affects visibility, but does not exceed PM10. Natural 

phenomena like volcanic eruptions and windstorms over deserts also produce particulate matter. The

Bitterroot Valley air quality has been affected by dust from as far away as China in 1998 and 2001, and the 

Mount Saint Helens eruption in 1980. 

Activities/Occurrences with Similar Effects and Past, Present and Reasonable Foreseeable 

Actions

Metropolitan areas upwind like Seattle and Portland can affect particulate matter. Smoke and dust from 

agricultural areas like the Palouse Prairie and wheat growing area of eastern Washington and Idaho affect 

particulate matter in the Bitterroot Valley. Wind on wheat fields of southern Alberta and Saskatchewan, 

Canada, as well as, eastern Montana affects particulate matter in the Bitterroot Valley.

24 hour Maximum PM 2.5 Concentrations (Pile Burn)

0

1

2

3

4

5

0.10.30.50.70.91.11.31.51.7

1.9

Downwind Distance (Miles)

PM 2.5 Concentrations 

(Micrograms/cubic meter)

CPB6PP FPB6MC

GPB5PP HPB5PP

HPB6PP PM 2.5 Standard (ug/m3)

CPB5PP
Affected Environment & Environmental Consequences – Air Quality

3.4- 12 Lower West Fork Project Final EIS 

Table 3.4-3: Particulate Matter, PM2.5 and PM10 Produced (Tons) in Each Alternative over the Next 

15 Years

LWF 

Smoke 

Scenario

Unit# Unit Area 

(acres)

Alt2 Alt3

Modeled Sum 

of emissions 

produced

By 

Scenario Alt2 Alt3

Total Area 

Burned (acres)

Total Area 

Burned (acres) (Tons) (Tons/acre) PM2.5(Tons)

PM2.5

(Tons)

cub4pp 61 418 596 448 41.4 0.10 59.6 44.8

cub5pp 64 246 681 146 24.4 0.10 68.1 14.6

gub4pp 13 84 116 0 8.3 0.10 11.6 0

gub5pp 18 36 68 33 3.6 0.10 6.8 3.3

hub4pp 9 109 160 109 16.4 0.15 24.0 16.4

hub5pp 33 282 1,720 1,439 42.3 0.15 258.0 215.9

hub6pp 24 19 41 0 2.9 0.15 6.2 0

hub5mc 61A 415 721 676 296.3 0.71 511.9 480.0

hub6mc 60 134 295 162 65.6 0.49 144.6 79.4

cpb5pp 87 38 60 60 10.7 0.28 16.8 16.8

cpb6pp 92 27 73 73 7.6 0.28 20.4 20.4

fpb6mc 91 28 28 28 7.9 0.28 7.8 7.8

gpb5pp 95 43 167 167 12.1 0.28 46.8 46.8

hpb5pp 89 61 176 176 17.2 0.28 49.3 49.3

hpb6pp 80 24 65 53 6.8 0.28 18.2 18.2

Total area burned1 (acres) 467 3,582 Total PM2.5 Emissions 

(tons) 1,250 1,014

Total PM10 Emissions 

(tons) 1,563 1,268

1 Area burned includes maintenance burning.

Private burning of ditches and debris is common. Ravalli County’s open burning regulations limit the types 

of material that may be burned and the period of burning (March 1 through November 30). Burners are 

also requested to call the Ventilation Hotline during the fall months to be advised of airshed burning 

restrictions. Although the Bitterroot National Forest conducts prescribed burning only during periods of 

good or better smoke dispersion, there may still be some cumulative smoke impacts from burning under the

action alternatives and concurrent private and forestry burning. We will advise the Airshed Group of our 

prescribe fires to coordinate burning projects with other land ownerships and reduce cumulative smokerelated impacts.

There would be no cumulative effects on air quality under this alternative.

Alternative 1

Alternative 2 would most effectively reduce potential smoke emissions and associated pollutants from 

large, uncontrolled wildland fires in the long term because fuels would be treated over more area. 

Although this alternative would produce the highest smoke emissions over the next 15 years, those 

emissions would take place with approval of the Airshed Group, which would reduce impacts to people and 

communities as compared to uncontrolled wildfires. Alternative 3 has the lowest smoke emissions of the 

Alternatives 2 and 3
Affected Environment & Environmental Consequences – Air Quality

Lower West Fork Project Final EIS 3.4 - 13

action alternatives over the next 15 years because less area would be treated. With less area treated under 

Alternative 3, the potential for higher smoke emissions and associated pollutants from large, uncontrolled 

wildland fires increases. 

Burning activity proposed in the action alternatives show summed values of particulate matter as if all 

burning were taking place at one time—all broadcast burns in one spring period and all pile burns in one 

fall period. This is unlikely to happen given the constraints of weather and air quality conditions that 

dictate when burning and the completion of treatments can occur. Because of these constraints, the 

prescribed burning is likely to occur over the next 15 years, making less cumulative smoke impacts at any 

one time and location than are modeled.

With the advent of modern fire suppression in the 1940s, impacts to air quality changed from regional haze 

to local/regional peak emissions events during wildfire. This is because fires burned frequently at low 

intensities for long periods, and fuel loads were low prior to the fire suppression policy. With fire 

suppression, fuels loads increased. Presently, fires are either suppressed when small and emit little smoke,

or they escape control and the high fuel loads create large, high intensity events that produce a large 

volume of smoke over a shorter period of time. Either of the action alternatives will begin to reverse this 

trend. Reducing fuel loads allows fire to burn at lower intensities and without the large events that produce 

most of the smoke emissions.

The direct smoke effects from prescribed fire will last 1-3 days depending on the length of the smoldering 

phase and strength of surface and transport winds. Greater amounts of ground and surface fuels are 

consumed when the smoldering phase occurs for a longer period.

3.4.5 CONSISTENCY WITH BITTERROOT FOREST PLAN AND OTHER REGULATORY 

DIRECTION

All prescribed burning would be implemented in full compliance with Montana and Idaho DEQ air 

programs through cooperation with the Montana/Idaho Airshed Group.

The Bitterroot National Forest Plan includes air quality goals, standards, and management direction that are 

to “maintain existing air quality.” The Bitterroot National Forest cooperates with the Montana air quality 

regulators through the State Implementation Plan. Furthermore, the Bitterroot National Forest participates 

in the state of Montana smoke management program to meet National and State air quality standards for 

PM10 and PM2.5. This project meets or exceeds all criteria to protect air quality.
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-1 

3.5 SOILS

This section describes the soil resources in the Lower West Fork Project area in terms of:

Ø The extent of detrimental soil disturbance (DSD) from past and present management activities in 

activity areas or treatment units (existing soil condition); and

Ø The potential for management activities in the Proposed Action and alternatives to create additional 

DSD in treatment units (environmental consequences). 

DSD is defined in Forest Service Manual, FSM 2500 R-1 Supplement No. 2500-99-1 (PF-SOILS-001). 

Comprehensive descriptions of the Regulatory Framework, the analysis area, methodologies, and research 

findings are in the Soils Project File.

3.5.1 SCOPE OF ANALYSIS AND ANALYSIS METHODS

The soils analysis area encompasses all land within an individual treatment unit. In general, soils outside 

the activity area (treatment unit) boundaries are not expected to be directly, indirectly, or cumulatively 

affected by this proposal; no harvest or post-harvest equipment would operate off system roads outside the 

unit boundaries. Several proposed temporary roads would be constructed outside the treatment unit 

boundaries and are included in the delineation of “activity areas” and the effects discussions. 

Sources of information used in the description of soil resources include: 

Ø Field assessment of existing soil conditions that were conducted by a professional, journey-level 

soil scientist. 

Ø Soils within the analysis area have been mapped and are described in the Bitterroot National Forest 

(Bitterroot NF) Land System Inventory (NRCS soil survey).

A. Assessment of Existing Soil Condition and Detrimental Soil Disturbance

Commercial thin units were initially field reviewed using a walkthrough survey (PF-SIL-010). The 

walkthrough survey provides an initial overview of each unit and identifies past management activities 

such as timber harvest and any Detrimental Soil Disturbance (DSD). The Region 1 Soil Monitoring 

Protocol (DRAFT - The 2007 Northern Region Soil Quality Monitoring Protocol, 6-15-07, Version 3.1) 

was applied to determine the severity and the extent of soil disturbance in the unit if DSD was identified. 

Commercial Thinning Units

Under the Region 1 Soil Monitoring Protocol, the Forest Service records soil conditions along randomly 

oriented transects at pre-set sample intervals within the treatment area. The Soil Scientist records soil 

information such as surface cover, displacement, compaction, and structure at each sample site. He tests 

soil compaction by observing the penetration resistance of a tile spade in the soil (PF-SOIL-002). Soil 

conditions in specific units are described in section 3.5.3-B. 

The Soil Scientist did walkthrough surveys on the proposed non-commercial thin and prescribed fire units 

(PF-SOIL-010). The walkthrough survey provides a representative view of each unit and ensures these 

units do not currently exceed R1 soil quality guidelines. The Region 1 Soil Monitoring Protocol was not 

used on these units since non-commercial thins and prescribed fires typically do not use ground-based 

equipment and cause DSD. Further discussion of existing conditions in these units is included in section 

3.5.3–B. 

Non-commercial Thinning and Prescribed Fire Units

3.5.2 REGULATORY FRAMEWORK

The Bitterroot NF Plan (Forest Plan), FSM 2500, and FSM 2550, provide management direction for soils 

within treatment areas. This direction is in the following documents and a summary of the Regulatory 
Affected Environment & Environmental Consequences - Soils

3.5-2 Lower West Fork Project Final EIS

Framework is in section 3.5.5. 

Ø The National Forest Management Act

Ø The Forest Plan (USDA Forest Service 1987) 

Ø Forest Service Manual (FSM 2550). 

Ø FSM 2500 – R-1 Supplement R1 2500-99-1 

Ø Montana State Guidelines for Best Management Practices (BMPs) (Appendix A) 

Ø Soil and Water Conservation Practices (SWCPs), Forest Service Handbook (FSH) 2509.22 

(Appendix A) 

3.5.3 AFFECTED ENVIRONMENT

A. Soil Characteristics, Potentials, and Limitations to Management 

The West Fork of the Bitterroot River (West Fork River) divides the project area and flows from the 

southeast to the northeast. The landscape west of the river consists of steep mountain slopes along the 

southeast flanks of Trapper and Boulder Peaks. These peaks are some of the tallest in the Bitterroot Range 

with Trapper Peak being the tallest at 10,157 feet. These slopes are typical of the relatively straight and 

continuous slopes of the Bitterroot Front, and are dissected by the Pierce, Baker, Lloyd, Christisen, 

Boulder, and Ward drainages. With the exception of the Boulder drainage, these drainages originate on the 

slopes below the peaks and form small watersheds that drain southeast to the river. The Boulder drainage 

forms the divide between Trapper and Boulder Peaks and is by far the largest drainage west of the river. 

Alpine glaciers that often advanced to the outlet of the drainage at the West Fork River during past glacial 

events extensively carved this U-shaped drainage. 

Physiography

Shook and Rombo Mountains define the landscape to the east of West Fork River. These peaks do not 

extend above 8,400 feet, but still contain rugged terrain and steep slopes. In general, these slopes are more 

broken by ridgelines and drainages than the slopes along the Bitterroot Front. These slopes also have the 

full range of aspects from 0 to 360 degrees. The watersheds east of West Fork River are defined by East 

Piquett, Piquett, Violet, Pine, Applebury, Steep, and Castle drainages. The Piquett watershed is the largest 

and extends from the southernmost tip of the project area north to the West Fork River.

Idaho Batholith granitics dominate the geology of the analysis area. These materials decompose to coarse 

textured soils typically ranging from loamy sands to sandy loams. Loam textures are found in areas of finer 

textured granitic soils or in places where more extensive weathering has occurred. Soils on the slopes are 

young having formed since the last glaciation approximately 10,000 years ago, and have limited 

development. In many areas, the soil profile contains a high percentage of coarse rock fragments from 

colluvial and/or glacial processes. High surface rock content is present in many locations.

Soils on north and east facing aspects are generally deep (greater than 24 inches) and support productive 

forests. Deep soils with coarse surface textures (sandy control sections) can be sensitive to erosion if 

ground covering litter and vegetation are damaged or removed. Recovery of these soils occurs at a faster 

rate than the shallow soils on ridgelines and south facing slopes due to biomass production and subsequent 

soil organic matter accumulation. Inclusions of soils with fine surface textures - loamy, fine-loamy, and 

fine control sections, occur in the project area and can be sensitive to soil compaction from ground-based 

harvest equipment.

Soils on south and west facing aspects typically have shallow soils (less than 10 inches to bedrock/parent 

material); this is especially true along ridgelines and steep nose ridges east of West Fork River. These 

areas are often associated with cliffs and exposed rock outcrop. The shallow soils have lower site 

productivity, lower vegetative cover, and inherently lower effective soil cover than more developed, deeper 

soils on north and east facing slopes. The protective litter and duff layer of these soils is often 

discontinuous and less than one inch thick. Due to dry and low productivity soils, grasslands are often 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-3 

found along ridgelines and south facing slopes. Soil properties are included in PF-SOILS-003. 

The Forest Plan determines suitable land with the recognition that there are unsuitable land inclusions 

within this broader designation. The identification of these inclusions and their significance is determined 

at the project level. Determination of suitability within each unit was completed with the premise of “the 

growing, tending, harvesting, and regeneration of crops of trees...” (NFMA 1976). Areas of rock fall, talus 

slope, and shallow, droughty soils were identified in some of the prescribed burning units. Many of these 

locations were very small or had slight limitations and burning activities will not affect them. As stated in 

the Forest Plan, salvage can occur on unsuitable lands to meet the goals and standards of the management 

area (MA1 pg. III-5(e (8)) and MA 3a pg. III-18(e(7))) and meeting cover/forage objectives (MA2 pg. III 

11(e)(1)).

Suitable Lands

The Nez Perce Fork Vegetation Management Project (1998) included treatment units that overlap the 

Lower West Fork project and soils data collected in these units is used in this analysis (3.5.3-B). The Nez 

Perce project was analyzed in an Environmental Assessment (EA) but the Decision Notice was not 

completed because of the 2000 fire season and subsequent Burned Area Recovery project. 

Previous Data Collection in the Project Area

We assessed the potential management limitations of soils in the project area using the soil and landtype 

mapping information in the Bitterroot NF Soil Survey (NRCS MT647). All proposed treatment units were 

assessed using the Natural Resource Conservation Service (NRCS) soil interpretations and include: 

Landtype Mapping and Interpretation

Ø potential erosion hazard

Ø potential rutting hazard (compaction) 

Ø potential seedling mortality (regeneration potential) 

Ø potential fire damage hazard 

Limitations on harvest equipment operability were analyzed using NRCS soil interpretations. In most 

cases, the limiting factor was slope. Forest Plan Standards (FEIS IV-43) address this limiting factor by 

restricting tractor yarding to slopes less than 40 percent. Typically, ground-based operations on the 

Bitterroot NF are restricted to slopes less than 35 percent to provide a buffer that ensures the 40 percent 

standard is not commonly exceeded.

Table 3.5-1 lists the proposed treatment units where NRCS interpretations indicate management activities 

may have high potential to affect specific landtype mapping units (LMUs). These interpretations have been

used to develop mitigations and assess effects of the alternatives later in this environmental analysis. 

NRCS soil interpretations were applied only to the dominant LMUs in the treatment units; LMUs that made 

up less than 15 percent of a treatment unit were considered too small to affect overall management 

prescriptions. For any given interpretation, if the soil components of a given LMU had conflicting 

interpretations, the most conservative (most limiting) landtype component was selected. 

Erosion is the potential soils concern most often listed for the proposed treatment units. The NRCS 

interpretation considers slope and the susceptibility of soil particles to detach and be transported by water. 

The decomposed granite soils in the project area are coarse textured and the soil particles have poor 

cohesion. Soil structure is often weak and provides little protection from eroding forces. These soils are 

highly erodible on slopes greater than 40 percent when mineral soils are exposed. 

Potential fire damage is listed as a concern for several soils due to the shallow surface organic horizon. In 

many cases, these soils have less than an inch of organic material overlying mineral soil. The thin organic 

horizons play a critical role in nutrient cycling, microbiological activity, and future soil development. 

Severe fires can reduce the productivity of these soils and may lead to erosion on steep slopes. 
Affected Environment & Environmental Consequences - Soils

3.5-4 Lower West Fork Project Final EIS

Table 3.5-1: Landtype Mapping Units (LMUs) with Potential Limitations for Management Activities. 

The Data is based on NRCS Soil Interpretations with High to Very Severe Ratings.

LMU1 LMU Included in Units: Potential Limitation for Management 

Activities

13B10 85 Regeneration

30B18 14, 15, 21, 28, 60, 89, 102 Erosion

30B31 22, 71, 75 Erosion

30B33 4 Erosion

30D16 92 Erosion

30D18 21, 25, 26, 28, 33, 88, 89, 98, 102 Erosion and Rutting (Compaction)

30D30 13, 75, 85, 88 Erosion

30G43 33, 60, 80 Erosion

30K18 29, 74 Erosion

30K31 66 Erosion

31B15 2, 4, 5, 6, 8, 9, 15, 21, 23, 24, 33, 34, 35, 

41, 42, 61, 62, 64, 66, 68, 84, 90, 92, 93 Erosion

31B39 16, 26, 65, 74, 91 Erosion and Rutting (Compaction)

31B70 1, 9, 10, 11, 12, 18, 19, 20, 34, 61, 63, 

68, 72, 73, 94, 97, 100, 101, 63B Erosion

31D15 27 Erosion

31D28 16 Erosion and Rutting (Compaction)

31D70 13, 85, 86, 87, 88, 95, 96, 99 Erosion

31K56 29, 40, 65, 69, 100, 60A Erosion

32D41 81, 93 Fire Damage

33B30 3, 7, 14, 18, 19, 24, 68, 72, 94, 63B Regeneration

44B16 8, 33, 34 Fire Damage

49B15 70 Erosion and Fire Damage

49D43 32 Erosion

61B11 60A Erosion 1. Landtype Map Unit (LMU) contains data for soils and landtypes within each unit. Descriptions of these LMUs are 

located in the project file (SOIL-003).

Regeneration limitations are noted for several soil and landtypes in the project area. The regeneration 

limitations are caused by shallow soils with very limited water-holding capacity.

Several soil types have low soil strength and are prone to compaction, based on NRCS interpretations. 

Ground-based operations during moist soil conditions typically create ruts in these soils. Soil texture, rock 

content, and ash component were analyzed to identify soils with potential compaction concerns in addition 

to the NRCS interpretations. Proposed treatment units with LMUs prone to compaction from ground-based 

harvest equipment are listed in Table 3.5-2. 

Fine textured soils are susceptible to compaction from ground-based equipment. Soils with clay 

concentrations exceeding 20 percent in the upper 12 inches of the soil profile are fine textured soils. In 

addition, soils with an ash-loam, ash-silt loam, and ash-sandy loam texture with less than 15 percent coarse 

rock fragments in the upper 7 inches of the soil profile are susceptible to compaction. Past ground-based 

harvest activities on these soil types would have caused compaction. Natural recovery of compaction in 

these fine textured soils is expected to take much longer than that in the coarse textured granitic soils. 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-5 

Table 3.5-2: Landtype Mapping Units (LMUs) with Compaction Potential.

LMU LMU Included in Units: Ash 

Surface1

High Clay % in Upper 

Soil Horizons2

13B10 13 (approx. 20 acres) and 41 (approx. 30 acres) Yes No

17B32 1 (approx 50 acres) No Yes

31K56 1 (approx. 60 acres) and in small portions of units (<5 to 10 acres): 

18, 22, 29, 42, 66, 69, 87, 88, and 99 No Yes

32B39 3 (approx 60 acres in N 1⁄2 of unit), small portions of units (<5 to 

10 acres): 61, 63B No Yes

36D43 64 (approx. 20 acres) Yes No 1. Ash Surface = Soils that have an ash-loam, ash-silt loam, and ash-sandy loam texture and less than 15% coarse 

fragment content in the upper 7 inches of the soil profile. 2. High Clay % in Upper Soil Horizons = Soils with greater than or equal to 20% clay in the upper 12 inches of the 

soil profile are at risk for compaction by ground-based equipment.

B. Site Conditions in Treatment Areas 

A professional soil scientist surveyed soils in the commercial thin units during the summer of 2007 and 

2008. Refer to the Methods section 3.5.1 for survey methods and assumptions. Soil monitoring followed 

the Region 1 Soil Monitoring Protocol. 

Commercial Thinning Units

DSD was only identified in three commercial thin units and the terrace units (Table 3.5-3). Units 1, 3, and 

12, and terrace units (14, 21, 25, 27, 35, 75, 81, 86, 88, 89, 90, and 99) are near or currently exceed 15 

percent DSD. Though DSD was evident in unit 12, monitoring indicates it is within soil quality standards. 

DSD was not identified in the remaining treatment units (Table 3.5-10). Table 3.5-3 displays information 

for units only where DSD was identified. Figure 3.5-1 (pg 3.5-8) displays where the DSD was detected in 

these units.

Table 3.5-3: Commercial Thinning Units with Detrimental Soil Disturbance (DSD). Data 

Based on Region 1 Soil Monitoring Protocol Completed by Professional Soil Scientist. 

Proposed Unit Unit Area

(Acre)

Existing DSD

(Acre)

DSD

(% in Unit1)

1 221 42 19 

3 163 55 34

12 125 9 7 

Terrace Units

14, 21, 25, 27, 35, 75, 81, 86, 88, 89, 

90, and 99

Combined Area for 

Terrace Units = 297

Combined DSD for 

Terrace Units = >150 >50%

1. This column represents the amount of DSD within the proposed treatment units (FSM and Region 1 

Handbook definitions) and thus directly equates to Region 1 soil quality guidelines.

Additional vegetation management in these units will require soil rehabilitation in order to comply with 

Region 1 Soil Quality Standards (R1 SQS). The R1 SQS state: In areas where more than 15 percent 

detrimental soil conditions exist from prior activities, the cumulative detrimental effects from project 

implementation and restoration should not exceed the conditions prior to the planned activity and should 

move toward a net improvement in soil quality.

Unit 1: DSD was approximately 19% of Unit 1and was created primarily by an extensive skid trail 

network from past timber harvest in the gentle sloping terrain in the central portion of the unit. This 

heavily disturbed portion of the unit is located below NFSR 363 and covers approximately 65 acres. The 

soils in this location have high clay concentrations (18 to 30%), which are sensitive to compaction and are 

Description of DSD in Commercial Thinning Units
Affected Environment & Environmental Consequences - Soils

3.5-6 Lower West Fork Project Final EIS

noted in the soil survey data (Table 3.5-2). These compacted clay soils exhibit little natural recovery from 

past timber harvest. In addition to high clay content, these soils have a high concentration of stones and 

boulders, which limits rehabilitation options. 

Unit 3: The clay-rich soils in this unit has been highly compacted from past ground-based logging 

activities (DSD = 34%). High clay content soils are noted in the northern half of the unit (Table 3.5-2). 

Most of the disturbance is confined to historic skid trails.

Unit 12: DSD was approximately 7% and most of the disturbance is located in the northwest corner of the 

unit. Compaction is still evident on several skid trails in this area. No bare soils were observed and 

vegetation growth was robust on the compacted skid trails. 

Terrace Units: Units 14, 21, 25, 27, 35, 81, 86, 88, 89, 90, and 99 were all terraced during the late 1960s. 

Region 1 Soil Monitoring Protocol was completed on units 35 and 81. Terracing activities greatly disturbed 

soils in these units. Dozers were used to cut the terrace benches into the slopes. Topsoil from the benches was 

side cast down the risers (slope in between benches) creating a high amount of soil displacement. The benches 

were heavily compacted by the dozers. Recent monitoring of terrace units 35 and 81 indicate that the majority 

of disturbance was on the terrace benches where compaction is high. Soils between the benches (risers) are 

relatively undisturbed with diverse and productive native plant communities. DSD for units 35 and 81 was 

about 53% and 57% respectively. All other terrace units (14, 21, 25, 27, 86, 88, 89, 90, and 99) were not 

monitored with the Region 1 Soil Monitoring Protocol. A walkthrough was completed on these units to note site 

conditions. The walkthrough surveys found that disturbances from the terracing activities are consistent 

throughout the terrace units in the project area. Based on protocol data for units 35 and 81 and walkthrough 

surveys, the remaining terrace units are all estimated to have approximately 50 to 60% DSD (Previous 

Monitoring - Nez Perce Fork Vegetation Management Project).

In addition to the units listed in Table 3.5-3, field reconnaissance completed during the Nez Perce Fork 

Vegetation Management Project in 1998 identified DSD in units that overlap with proposed commercial 

thinning units in this project (available for review at Forest Supervisor’s Office). Data overlap occurs 

mostly in Unit 3, and in portions of Units 12 and 34 of the Lower West Fork project. DSD levels detected 

during the Nez Perce project were considerably higher than those recently observed using the Region 1 Soil 

Monitoring Protocol. Soil monitoring in the Nez Perce project did not follow the Region 1 Soil Monitoring 

Protocol. Less DSD was also observed during recent monitoring due to natural recovery of soils that has 

improved conditions in these areas since the Nez Perce surveys. 

Walkthrough surveys completed for the non-commercial thinning units have identified past disturbances 

only in terrace unit 75. This terrace unit is expected to have 50 to 60% DSD similar to all other terrace 

units in the project area. The walkthrough surveys of several prescribed fire units indicate there is little to 

no DSD from past harvest activities. These units are located in areas that were typically avoided by past 

harvest due to the difficulty of logging. 

Non–Commercial Thinning and Prescribed Fire Units

C. Other Effects on Existing Soil Condition in the Project Area 

The Rombo Mountain fire was ignited by lightning in July 2007 near Rombo Mountain. The fire burned 

approximately 30,000 acres on both the West Fork and Sula Ranger Districts. Most of the fire burned in 

the eastern half of the Lower West Fork analysis area. Portions of the fire extended beyond the southern tip 

and eastern edge of the project area. The fire encroached on several proposed treatment units (units 14, 25, 

26, 27, and 88) in the Piquett and East Piquett watersheds. The fire effects in these units ranged from low 

to moderate severity.

Effects of the Rombo Mountain Fire

Field reconnaissance of burn conditions was completed during the Burned Area Emergency Response 

(BAER) assessment on September 24, 2007. The BAER team based the assessment on the burn severity 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-7 

map that was compiled from Burned Area Reflectance Classification (BARC) data. The burn severity map 

indicates areas of low, moderate, and high fire severity. The breakdown of burn severity within the fire 

perimeter is shown in Table 3.5-4 and Figure 3.5-1 (pg 3.5-8). 

Table 3.5-4: Rombo Fire Burn Severity Analysis based on Burned Area 

Reflectance Classification (BARC) Data. 

Burn Severity Acres1 Fire Area (%)

High 6,561 22

Moderate 9,789 36

Low 6,671 22

None 6,055 20 1. Acres shown are those within the Rombo fire perimeter, not the Lower West Fork Project boundary.

The BAER team focused field efforts on the intensively burned areas in combination with some moderately 

burned areas. The team evaluated soil and watershed indicators to rate burn severity and potential 

excessive watershed response. The soil characteristics reviewed were degree of hydrophobicity, ash color, 

ash depth, soil color, texture, coarse fragment content, and erosion potential. Soil hydrophobicity was 

correlated with the burn severity data to determine areas with the highest soils impacts.

Burned area soils assessment indicated the burn severity map (BARC data) correlated well with the degree 

of hydrophobicity identified in soils. High severity burn areas typically displayed moderate to high 

hydrophobicity. Moderate severity burns had low to moderate hydrophobicity, while low severity burns 

had low to no hydrophobicity.

Areas of low and moderate severity burns had minimal effects on soil productivity and erosion. These 

areas contained patchy burn characteristics with live or regenerating vegetation. Surface organic horizons 

were partially burned to fully consumed. Needle cast potential from damaged and fire killed trees is high in 

many areas. This needle cast will provide erosion control on exposed mineral surfaces and organic material 

for initial soil recovery. 

Native grasses and forbs have recovered across most of the fire with the exception of a few high severity

areas. High severity burned areas with poor vegetative recovery have the potential for soil productivity loss 

and elevated erosion. The fire completely consumed organic horizons in these areas and hydrophobicity 

was common at a 2 inch depth in the mineral soil profile. Reduced infiltration in these soils may cause

higher than normal runoff and erosion. The increased runoff and erosion may in turn cause debris torrents 

in stream channels that have been intensively burned. Surface rock cover, estimated at 15 to 20 percent in 

the high intensity burn areas, will minimize erosion. In addition, partially burned logs and downed trees 

are abundant in the high severity burn patches and create breaks in the slope that slows runoff velocity and 

limits erosion. 

The soils assessment of the burned areas determined that no emergency restoration was necessary (SOILS004). Water Erosion Prediction Project (WEPP) modeling using the Erosion Risk Management Tool 

(ERMIT) did not indicate that seeding or other erosion control measures would substantially reduce 

potential erosion from the burned areas (SOILS-005).

The large-scale fires that occurred on the Bitterroot NF in 2000 overlay approximately 3,500 acres of the 

analysis area (Figure 3.5-1). However, only 420 acres burned under high severity fire. Erosion of mineral 

soils has occurred in some high severity areas but has since stabilized by revegetation. Observations by the 

soil scientist indicate soils in these areas are recovering slowly. These areas are slowly accumulating 

organic material but require additional accumulation and decomposition to re-establish the surface organic 

horizons. Recovery of organic horizons on the coarse textured soils coupled with the dry, cool climate 

limits the potential for organic development in these soils, as is the case across much of the Bitterroot NF

Effects of the Fires of 2000

Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-11

3.5.4 ENVIRONMENTAL CONSEQUENCES

Soil disturbance is an unavoidable consequence of forest management activities. BMPs and mitigations are 

applied to reduce disturbance and limit the resource management effects on soil resources, however, it is 

not entirely possible to eliminate disturbance. Resource management effects can be both direct and 

indirect, and may alter the physical, chemical, and/or biological properties of soil. Physical properties that 

may be altered include soil structure, density, porosity, infiltration, permeability, water holding capacity, 

depth to water table, surface horizon thickness, and organic matter size, quantity, and distribution. 

Chemical properties include changes in nutrient cycling and availability. Biological properties include 

abundance, distribution, and productivity of the many plants and animals that live in and on the soil and 

organic detritus.

Soil compaction, displacement, puddling, burning, erosion, and mass wasting cause the greatest adverse 

effects on the physical, chemical, and biological properties of soil. Management activities directly affect

soils when they cause compaction, displacement, puddling, and burning. Erosion, mass wasting, and 

changes in water table, soil biology, organic detritus recruitment, and fertility (such as the fertilization 

effects of ash after a light-severity fire) are typically indirect effects.

Direct and indirect effects of the proposed activities on soil resources are analyzed in terms of:

1. soil productivity; and 

2. soil disturbance (DSD by treatment units).

Cumulative effects are considered for all past, present, and reasonably foreseeable activities that affect soil 

properties within treatment areas.

The primary concerns are the direct and indirect effects of management activities on soil productivity and 

disturbance (Forest Plan pgs. II -24, 25 # 6, 7, 8, and 9). Productivity loss associated with any action is 

influenced by the degree, extent, and duration of adverse soil conditions within and adjacent to each 

treatment area. Degree refers to the magnitude of change in soil properties, such as an increase in bulk 

density or a decrease in macroporosity, and the depth to which these changes occur. Extent refers to the 

area affected by such changes. Duration refers to the length of time such changes may persist on or 

adjacent to the site. 

The criteria used to determine direct, indirect, and cumulative effects on soil productivity is the percentage 

of area within a treatment area where DSD has occurred or is anticipated from proposed activities. DSD is 

defined in Forest Service Manual, FSM 2500 R-1 Supplement No. 2500-99-1 (SOILS-001).

Soil productivity is a site specific characteristic and is evaluated in each treatment area. Loss of soil 

productivity in a treatment area alone will not lead to a loss in soil productivity in an adjacent stand or other 

areas elsewhere in a watershed. Soil productivity is a highly site-specific variable and dependent on a 

number of climatic characteristics and soil forming factors that occur at very small scales. Soil productivity 

can vary from one square foot to the next with each area functioning independently. Thus, the highly 

variable and independent nature of soil productivity requires site-specific analyses to maintain the proper 

context. Assessment of cumulative effects on soil productivity at scales larger than the treatment area 

boundary (such as the watershed scale) also misrepresents the effects of management activities by diluting 

the site-specific effects across a larger area. In contrast to soil productivity, erosion and hydrological 

processes function at watershed scales and are analyzed in the Watershed Section 3.6. 

Discussion concerning the amount of project area previously harvested and effects on the soil resource at 

the landscape scale is included in the Soils Section 3.5.4 C (Cumulative Effects for All Alternatives).

A. Direct and Indirect Effects for Alternative 1 – No Action 

Alternative 1, No Action, maintains the existing condition of the project area and provides a base line to 

evaluate the effects of the action alternatives. The effects on soils are discussed as changes over time on 
Affected Environment & Environmental Consequences - Soils

3.5-12 Lower West Fork Project Final EIS

soil productivity, which includes soil properties of organic matter, groundcover and large woody material, 

nutrient cycling, soil erosion, and soil disturbance. Soil disturbance evaluations identify physical changes, 

including detrimental compaction, displacement, puddling, and severe fire; and changes in hydrologic 

function. 

Soil Erosion and Mass Movements 

Soil Productivity

The No Action Alternative would not alter the current soil erosion and mass wasting regimes in the project

area. Natural and human caused fires will likely continue to affect the project area and consume the 

protective litter and duff layer on the soil surface (PF-SOIL-006). 

Soil erosion and mass movement have been low in areas of low severity fire on the Bitterroot NF (based on 

monitoring conducted on the Forest over the last 15 years). Aerial surveys one year after the 1996, 40,000-

acre Swet fire on the Bitterroot NF found 4 minor slumps or debris flows and one larger debris flow over 

the entire burn area (Decker, 1997 Report, SOIL-007). No subsequent erosion events have been 

documented. Severe and moderate burns were prevalent in this fire. Except for the Fires of 2000, other 

fires in the past 15 years on the Bitterroot NF have been much smaller. They were typically less than 

10,000 acres and ranged from several hundred to a couple thousand acres. No large erosion or debris flow 

events resulted from these fires, except for the Gold Creek fire where a few large debris flows took place in 

severely burned areas.

Larger fires and those of moderate or high severity may cause soil erosion and mass movement depending 

on ground conditions and storm activity (Parrett et al. 2003). Soil erosion occurs where ground cover, duff, 

and litter are consumed, or hydrophobic soil conditions develop. Mass movement occurs primarily in the 

form of debris torrents within channels following high severity, short duration storm events (SOIL-006). 

Numerous soil erosion and mass movement events, triggered by intense thunderstorms, occurred on high 

severity burns after the Fires of 2000. The extreme fuel/fire spread conditions associated with the 2000 

fires coupled with high intensity thunderstorms, created optimal conditions for the resulting erosion/debris 

flow events.

Quantification of potential soil loss through post-fire erosion and mass movements is speculative because 

so many independent variables (fire severity, climate, soil types, soil effects, etc.) need to be incorporated 

into the predictions. Thus, discussions will be qualitative based on monitoring, research, and professional 

judgment. 

In summary, if future fires are within the historic range of variability, long-term effects of erosion and mass 

movement are likely to be relatively small. Fire severity exceeding the historic range of variability could 

have detrimental effects on erosion and mass movement through the alteration of soil hydrology and loss of 

soil organic matter and tree roots. 

Organic Matter, Groundcover, and Coarse Woody Residue 

The No Action Alternative would allow all standing trees, dead and alive, to shed needles and fine branches 

that would accumulate on the soil surface. Eventually, trees would fall to the ground, contributing coarse 

woody organics to the soil. Soil organisms would slowly decompose the organic materials, adding 

beneficial humus to the soil. The primary source of soil organic matter is the decomposition of fine roots 

rather than the decomposition of surface organics (Powers, et. al. 2004). Nutrients associated with this 

material would slowly become available for plant growth. This process would continue until another major 

disturbance, such as fire, consumes or partially consumes the accumulated litter, duff, and woody material. 

Long-term effects on soil health and productivity are likely to be relatively small from future fires that are 

within the historic range of variability (Brown et al. 2001). Fire severity exceeding the historic range could 

have detrimental effects on soil productivity and health through the oxidation and loss of soil organic 

matter and associated soil biota, as well as through accelerated rates of erosion (Harvey et al. 1987; Harvey 

et al. 1988; Hungerford 1995). 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-13

Following the Fires of 2000, Brown et al. (2001) recommended the following “optimal levels” of coarse 

wood in burned areas: 

Ø 5-15 tons/acre on warm, dry ponderosa pine and Douglas-fir habitat types 

Ø 10 to 25 tons/acre on cool, dry to moist Douglas-fir, lodgepole pine, and lower elevation subalpine 

fir habitat types 

Optimal levels account for the historic range of variability in fuel loadings, fire responses to these loadings, 

and to climatic factors of the past few hundred years of the pre-settlement period, as well as the risks to 

resources and firefighters. Coarse woody debris recommendations in Brown et al. (2001) are consistent 

with those of Graham et al. (1994) and Harvey et al. (1981) for unburned Rocky Mountain forests. 

Under the No Action Alternative, fuel loads in the project area represent a fire regime condition class that 

has been altered by management activities and also one that has been absent of recent fire (Fire Section 

3.3). As a result, fuels loads are higher in specific areas and a fire would cause severe soil effects. Severe 

burns would have negative soil impacts, for example organic matter and soil nutrient loss, soil erosion, and 

subsequent weed invasion.

Nutrient Cycling

Microorganisms would continue to populate the soils, contributing towards site productivity through 

nutrient cycling and reforming soil aggregates in areas of detrimental compaction or displacement. During 

the field survey, no obvious nutrient shortages were noted. 

The No Action Alternative would cause no additional soil compaction, rutting, puddling, or soil 

displacement. Surface layer recovery (0 to 6 inches) has occurred over periods of 20 to 40 years based on 

soil quality monitoring across the Forest over the past 15 years. Soil productivity in the soil surface 

horizons has improved through plant root expansion, soil organism activity, and incorporation of soil 

organic matter. Bulk density recovery of sandy loam soils on the Bitterroot NF corresponds with data 

collected by Froehlich (1985). Froehlich noted that full recovery of the surface layer (0-2 inches) occurred 

within 20 years on sandy loam soils. 

Soil Disturbance

Recovery of compacted soil horizons below the surface (6 - 12 inches) has been observed in longer time 

frames (approximately 40 - 50 years) on the Bitterroot NF. At depths greater than 6 inches, the soil 

compaction is slowly recovering through natural processes. Spatial distribution of compaction at the 6 to 

12 inch depth varies across the landscape due to levels of historic use and variations in soil texture and 

moisture. Detrimentally compacted features include strong to moderately strong platy structure, low 

infiltration rates, high cone penetrometer resistance, and high rupture resistance. Periods greater than 50 

years may be required to improve soil structure on these heavily used skid trails. Froehlich (1985) 

regression data indicates that in sandy loam soils, it would take 40 to 50 years to naturally reduce bulk 

density levels to baseline conditions. The No Action Alternative will continue this natural recovery 

process.

Full recovery of organic-rich mineral soil horizons caused by historic soil displacement activities is a slow 

process. Clayton and Kennedy (1985) have estimated that it may take more than 50 years to restore organic 

matter to previous levels in disturbed forest ecosystems in central Idaho. However, data from the Long 

Term Soil Productivity study (Page-Dumroese, et. al. 2006) indicates that organic matter removal and 

increased compaction do not have a significant effect on mineral carbon and nitrogen pools five years after 

disturbance occurs. Jurgensen et al. (1997) also noted that soils with higher amounts of organic matter 

incorporated in the mineral layers, such as those present on the Bitterroot NF, are less affected by 

displacement and compaction than those soils with high amounts of surface organic matter (duff). 

Accumulation of soil organic matter is dependent on vegetative biomass accumulations that occur on the 

disturbed sites. Biochemical alteration turns raw biomass (duff and litter) into soil humus, the stable, 
Affected Environment & Environmental Consequences - Soils

3.5-14 Lower West Fork Project Final EIS

highly beneficial product of decomposition (Hungerford, 1995). Recent research indicates that much of the 

humification of upper mineral soil layers is a result of decomposition of dead fine roots (Powers, et. al. 

2004). 

B. Direct and Indirect Effects for Alternatives 2 and 3 

The effects on soils are discussed in terms of the magnitude, duration, and extent of change on soil 

productivity including soil erosion, mass movement, organic matter (groundcover, coarse woody material, 

and nutrient cycling), and soil disturbance. Soil disturbance evaluations look at physical changes that may 

affect productivity.

The proposed treatments include mitigation measures to minimize soil productivity reductions or soil 

disturbance. Furthermore, this effects analysis assumes that all of the State of Montana Best Management 

Practices (BMPs), Region 1 Soil and Water Conservation Practices (SWCPs) (FSH 2509.22, Appendix A), 

Forest Plan Standards, and Regional Guidelines will be implemented and effective. Soil technical support 

has been provided for all project alternatives throughout project design and planning. 

Soil Erosion and Mass Movement

Soil Productivity

Forests generally have very low erosion rates unless they are disturbed in a manner that exposes bare soils 

to the erosive energy of water. Management caused disturbances include prescribed fire, timber harvest,

and post-harvest operations. Soil erosion in harvest units is diminished by minimizing the amount of bare 

soils created by disturbance (Clayton and Megahan 1997; Robichaud et al. 2000). Practices such as leaving 

organic material on the soil surface, reducing the area of skid trails, and maintaining hydrologic function 

reduce potential soil erosion and maintain soil productivity (Appendix A). In addition, implementing 

specific erosion control measures such as water bars, placing slash on bare soils, and vegetating disturbed 

soils conserves the soil resource (Mitigations in Chapter 2, Section 2.3). Based on these erosion control 

measures, the proposed activities in the action alternatives will not lead to detrimental erosion or reduce 

soil productivity.

The project area does not contain LMUs with high risk of mass movement. The proposed thinning 

activities will not increase the risk of mass movement in the project area. Mass movement is dependent on 

slope, cohesion of soil particles, and loading forces such as moisture. Additional factors, such as root shear 

strength, provide structural reinforcement and buttressing on slopes (Gray and Megahan 1981). Roots 

remaining after trees are harvested will bind the soils to the underlying bedrock for approximately 5-7 years 

until root decay reduces root strength below the shear stress. 

Risk of mass movement from prescribed fire is also low. Prescribed fires are often ignited when soil 

moisture is high (greater than 80 percent) and weather conditions are cool and humid. Intense heating of 

the soil and complete consumption of organic soil horizons typically does not occur except in select cases 

where a log or accumulated fuels burn for extended periods. The probability of these small areas of 

disturbance altering slope stability is very low. It should also be noted that based on the burn prescription, 

mature trees are typically not affected during prescribed burning. The rooting systems of these mature trees 

would remain intact to provide soil stability. 

Organic Matter, Groundcover, and Coarse Woody Debris 

The action alternatives are designed to leave a variety of organic matter on the site. The practice of leaving 

organic matter on site provides for microbial populations, which maintain site productivity (Harvey et al. 

1994). Vegetation and organic matter protects the soil surface from raindrop impact, dissipates energy of 

overland flow, binds soil particles together, and dampens soil temperature extremes and daily fluxes. 

Studies have found that 60 percent effective ground cover substantially reduced sediment movement and 30

percent ground cover reduced erosion by half compared to bare soil (Robichaud et al. 2000). Logging slash 

will add to effective ground cover until fine logging slash decomposes over several decades (Clayton 

1981). Any increase in groundcover and/or fine logging slash through harvest may be offset by fuel 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-15

treatments. Fuel treatments may reduce the amount of organic matter and groundcover in the short-term (0-

5 years after treatment) through underburning or and burning slash piles. In the long-term (more than 5 

years), re-growth of vegetation and annual needle drop would provide groundcover and leaf and litter 

material for conversion into soil organic matter.

The timelines for surface organic matter recovery are based on monitoring observations of burned units on 

the Lil Lyman Salvage and Reforestation Project on the Bitterroot NF. Monitoring of these units was 

completed 3 to 5 years following the fires of 2000. Surface organic horizon depth, made up of surface litter 

and duff, was approximately 1 to 1.5 inches. Ground cover from large rock, duff, surface litter, and plants, 

averaged greater than 60 percent of the units except in Units 4 and 5 where the fire was more severe. Prior 

to the fires, organic matter in the top six inches of soil averaged 3-5 percent of the soil volume with a duff 

depth of 1 to 3 inches. 

In addition to project monitoring, research from the Sleeping Child burn found herbaceous cover increased 

up to five percent a year for the first 2 years (Lyons 1976, 1984). Lyons (1976, 1984) also found 

herbaceous plant cover was approximately 15 percent by year 3, 20 to 25 percent by year 6, and 60 percent 

by year 10. 

Displacement moves the forest floor and top soil from one place to another. In the absence of fire or 

erosion, the displaced material is not lost from the site. Page-Dumroese et al. (2000) reports that 

productivity losses from displacement, while initially high in localized areas less than 100 square feet, may 

not be significant to site sustainability when compared to losses from fire or erosion. Powers et al. (2004) 

noted that complete organic matter removal on long-term soil monitoring plots across the nation had no 

impact on total vegetative production at 10 years. 

Summer, ground-based harvest will reduce ground cover on heavily used landings and skid trails, and at 

trail junctions, and approaches to landings. An estimated reduction of ground cover of up to 10 percent has 

been analyzed for the ground-based units in this project. In order to minimize soil disturbances during 

harvest, historic skid trails will be used to the extent feasible in the ground-based units. The historic skid 

trails that are re-used will be decompacted upon completion of the yarding. On lightly used trails (one or 

two passes), ground cover is not anticipated to be reduced along the entire trail length. Constructing water 

bars, creating brush sediment traps, or seeding/planting forbs, grasses, or shrubs, will hasten groundcover 

recovery and reduce soil erosion and movement of soil off-site (Mitigations in Chapter 2, Section 2.3, 

Appendix A). Vegetation would re-establish in less than 5 years except where there is root kill. 

Summer Ground-based Harvest Effects

Groundcover in skyline corridors would be reduced approximately 5-10 percent because of choker setting 

cables and removing logs from the site (Clayton 1981; Klock 1975). In many cases, the displaced 

groundcover along the corridor occurs in small patches. These small areas (less than 100 square feet) of 

displacement are not considered DSD. Ground cover reduction would only occur along the corridor where 

log suspension is limited and numerous yarding passes occur. At landings, there would be additional 

reduction in groundcover due to equipment operations and corridor convergence. 

Conventional Skyline and Tracked Line Machine Harvest Effects

Loss of groundcover in the corridors and landings will be reduced by requiring partial suspension of logs

during yarding and ceasing operations during wet conditions. Corridors and landings will have soil 

rehabilitation treatments following logging and site prep activities. The timber sale contract would include 

treatments such as water bar construction and slash placement on bare soils in the corridors and landings 

where deemed necessary by the timber sale administrator. In the long-term, we anticipate that groundcover 

would re-establish in areas with soil displacement, with or without post-activity rehabilitation. 

Groundcover recovery would be achieved with needle cast and vegetation re-growth. 

Coarse Woody Debris

All harvest prescriptions would leave a portion of the existing stand on the site. Yarding will be either 
Affected Environment & Environmental Consequences - Soils

3.5-16 Lower West Fork Project Final EIS

whole tree or leave tops attached. Coarse woody debris, defined as material greater than 3 inches in 

diameter, will be left from designated leave trees, both standing and down, and from breakage of limbs and 

broken tops that occur during harvest. However, the treatments are designed to provide future coarse wood 

greater than 15 inches in diameter. Following the treatments, the stands will be capable of producing large 

coarse wood at a faster rate for soil development than current conditions. Large coarse wood persists for 

longer durations and provides greater benefits to soil development than smaller coarse wood. Large coarse 

wood is also much less of a concern for fire management. Currently, in many of the commercial thin 

stands, tree diameter at breast height (dbh) measures less than 15 inches; therefore, wood smaller than this 

will be required to meet coarse wood guidelines developed for this project. To the extent feasible, the 

largest coarse wood will be left on-site to satisfy coarse woody debris requirements for each treatment unit. 

Silvicultural prescriptions will account for additional trees that will be required for future coarse wood 

recruitment in the thinned stands.

The amount of coarse wood listed for each Fire Group will maintain future soil productivity (Table 3.5-5). 

Information about coarse woody debris developed for the Trapper Bunkhouse analysis pertains to this 

project as outlined in PF-SOILS-008. 

Table 3.5-5: Coarse Woody Debris (CWD) Requirements for Soil Productivity

The proposed fuel treatments are anticipated to leave slash on the ground through the winter and into late 

summer/fall before prescribed burning will be completed. This will allow the nutrients in the slash to be 

leached into the soil. 

Nutrient Cycling

Nearly all units proposed for harvesting will include whole tree yarding or leaving tops attached; the total 

acreage of these treatments is about 2,493 acres in Alternative 2 and 1,702 acres in Alternative 3. 

Regarding effects of whole tree harvesting on the growth of trees, Wells and Jorgensen (1979) believe that 

with long rotations, the depletion of the major nutrients needed by plants should not be excessive relative to 

total soil reserves, and the reserves would be replenished between cuttings. However, they also recognize 

that plant growth is dependent on the amount of nutrients actually available to the plants and that this 

available pool of nutrients can be in short supply in some circumstances. 

Wells and Jorgensen (1979) reviewed literature about nutrient pools and cycling in forest ecosystems. 

Their publication indicates that most of the total nutrient content occurs in the mineral soil. The majority of 

stands examined had 8 to 10 times more nitrogen in the soil reserves than in the trees. Nitrogen is typically 

the most limiting plant nutrient in forested ecosystems. The major natural nitrogen sources for replenishing 

the soil reserves is through mineralization of organic matter, atmospheric inputs, and nitrogen fixation by 

soil organisms. Jurgensen et al (1981) concluded there would be no long-term depletion of nitrogen 

reserves because lost nitrogen would be more than replenished by inputs from precipitation and by 

biological nitrogen fixation over a rotation of 100-150 years. 

Phosphorus is a critical plant growth macronutrient and is often only slowly available to plants. Its main 

sources are the weathering of soil minerals such as apatite, and organic matter decomposition. The 

phosphorus removal rate from timber harvest as the proportion of total phosphorus in the rooting zone is 

usually less than it is for nitrogen because an even larger proportion of total site phosphorus occurs in the 

soil than in above ground biomass. Morrison and Foster (1979) report on site nutrient distribution in a 

Pinus banksiana forest growing in sandy glacio-fluvial soil in Ontario. The percentage of site total 

nitrogen was 95 percent in the soil reserves and five percent in the tree canopy. For phosphorus, 99 percent 

of total site phosphorus occurred in the soil whereas only one percent was found in the tree canopy. 

Fire Group Description CWD 

2, 4 Warm, Dry Ponderosa Pine and Douglas-fir Habitat Types 5 to 10 tons/acre

6 Cool, Dry, and Moist Douglas-fir Habitat Types 10 to 20 tons/acre

7, 8, 9 Cool Lodgepole Pine and Lower Subalpine Fir Habitat Types 8 to 24 tons/acre
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-17

The status of other nutrients is unknown although there are no site indicators, which would point to a 

problem with nutrient availability or cycling in the units. Removal of potassium in whole tree harvests is 

modest in comparison to soil reserves according to Wells and Jorgensen (1979). Tree growth and ground 

cover is within the range expected for the site conditions. 

Page-Dumroese (2000) found that relatively small levels of disturbance (less than 15 percent of the area) 

resulted in relatively small losses in carbon, nitrogen, and cation exchange capacity (CEC), ranging 

between one and 13 percent of the available pools. She concludes that at these levels of loss, current soil 

quality guidelines appear to be adequate. This conclusion is based on initial research from the Long-term 

Site Productivity Project and results may change as more data is compiled.

Fire suppression in ponderosa pine has caused a build-up of forest litter and accumulation of organic matter 

(DeLuca 2000). DeLuca’s research has shown the positive benefits of reducing fuel loads and renewing the 

growth of desirable understory plants using fire, harvest, or a combination of both. Ponderosa pine 

communities commonly accumulate little inorganic nitrogen in mineral soil because of the slow decay rates 

and rapid uptake by plants and microorganisms. In addition, limited quantities of nitrogen may be 

available due to the accumulation of organic matter composed of woody residue, naturally low in nitrogen. 

Fire releases nitrogen, which makes it available to plants. However, a first entry of high severity fire may 

cause root kill and an overall reduction in nitrogen mineralization potential. 

DeLuca (2000) found prescribed fire following a selection or shelterwood harvest had a short-term increase 

in mineral nitrogen followed by a long-term decline in available nitrogen. This may seem like a negative 

impact of fire reintroduction; however, the reduced stand density has a lower nitrogen demand. In addition, 

there is a better Nitrogen:Potassium balance, which increases tree resistance to disease and insects. 

Retaining limbs and branches on site over the winter provides for nutrient leaching into the soil (Palviainen 

et al. 2004; Baker et al. 1989). Baker et al. (1989) found that there was little leaching of nutrients from live 

or dried needles immediately after harvest. However, he noted appreciable nutrient releases after 3 months 

of decomposition. Some of these nutrients may not be available to the remaining stands as they are used by 

organisms in the forest floor during decomposition. Researchers conclude that logging slash acts as a 

nutrient sink (Barber and Van Lear 1984). 

To summarize, by maintaining organic matter and ground cover on at least 85 percent of the treatment area, 

as prescribed in the Alternatives, nutrient cycling and availability would not be altered. The mitigations 

(Chapter 2, Section 2.3) and Region 1 standards and guidelines are prescribed to achieve this desired 

outcome. Localized losses may occur under burn piles, at landings, or in places of severe burning. 

Commercial thinning within proposed treatment units is designed to avoid detrimental soil impacts on more 

than 15 percent of the treatment area. This goal would be achieved by implementing mitigations described 

in Chapter 2, Section 2.3 as well as Montana BMPs and SWCPs (Appendix A). These design features and 

management practices would minimize the extent of compaction, rutting, puddling, and displacement. 

Soil Disturbance

Ground-Based Harvest Units or Portions of Units

Ground-based harvest is proposed on commercial thin units that have gentle terrain with slopes less than 35 

percent. All ground-based commercial thin units, except Unit 1, would be suitable for summer operations 

in Alternative 2. In commercial thin units with high existing DSD, winter ground-based operations are an 

excellent mitigation method to minimize soil effects; however, winter operations limit the ability to 

complete subsoiling activities. Winter operations could be completed in the majority of ground-based units 

if winter conditions are met (see soil mitigations page 3.5-28 & 29). Units 3 and 12 will require subsoiling 

of historic skid trails even if winter ground-based operations are utilized in order to create a net 

improvement in soil productivity in these units. 

A net improvement in soil productivity will also be required in unit 1; however, soils in unit 1 contain a 
Affected Environment & Environmental Consequences - Soils

3.5-18 Lower West Fork Project Final EIS

high level of coarse rock fragments, which are not conducive to subsoiling. Therefore, ground-based 

commercial thinning in Unit 1 will occur during winter in Alternative 2 to minimize further soil impacts. 

Higher levels of woody debris (15 to 20 tons/acre) will be left across the ground-based portions of the unit 

(approximately 65 acres) to improve soil organic levels that will alleviate compaction through natural 

processes over time. Table 3.5-6 displays a summary of ground-based harvest and potential acres of DSD 

for each alternative.

Table 3.5-6: Summary of Ground-based Activities and Potential DSD for each Alternative

Estimates of potential DSD for the action alternatives are based on monitoring (Bitterroot NF Soil Quality 

Monitoring 2002-2005, and 2006 DRAFT). Recent monitoring of timber sales using ground-based 

equipment during summer (no mechanical site prep) on the Bitterroot NF indicates that DSD ranges from 0 

to 10 percent, typically averaging 5 percent (Bitterroot NF Soil Monitoring 2002-2005). Soil quality 

monitoring (Summer 2006) on three different sales indicated that summer ground-based harvest added 0 to 

4 percent DSD (2006 DRAFT - Bitterroot NF Forest Soil Quality Monitoring). Soil disturbance values 

noted in literature correspond with Bitterroot NF monitoring data as soil disturbance was typically noted on 

less than 15 percent of the activity unit monitored (McNeel et. al 1992; Seixas 1995, McIver and Starr 

2000, Clayton 1990, Watt and Krag 1985, Klock 1975). Monitoring indicates that soil disturbance is not 

widespread but is generally limited to main skid trails and landings where there is more traffic.

Soils analysis in this project uses the conservative estimate of 10 percent DSD for summer ground-based 

yarding. The 10 percent estimate represents the upper end of summer ground-based harvest soil effects 

noted during recent monitoring on the Bitterroot NF. The 10 percent DSD estimate does not account for 

activities that reduce soil impacts such as reusing the existing network of skid trails. Rehabilitation of 

reused historic skid trails for the proposed harvest activities would cause a net improvement in soil quality 

in units with existing soil disturbance from past skid trails. Recent monitoring (Bitterroot NF Soil Quality 

Monitoring 2002-2005 and 2006 DRAFT) indicates that winter ground-based harvest causes approximately 

one percent DSD. Individual unit analysis is included in (PF-SOILS-009). 

Understanding Soil Compaction & Displacement during Ground-Based Yarding

Han-Sup et al. (2005), Steinbrenner (1955), Froehlich (1980 pg 29-36), Froehlich et al. (1983), Shetron et 

al. (1988) found that soil compaction results from the first few passes with mechanized equipment. Low 

pressure tracked or wheeled equipment may have stationary or static ground pressures as low as 7 pounds 

per square inch (psi). Once in operation, torque from pulling heavy loads, turning or forwarding motion 

increases ground pressures and thus compaction. Comparing rubber tired with tracked skidders, Clayton 

(1990) reported tracked vehicles had 50 percent greater dynamic pressure even though both types of 

equipment had equal static pressures. Soil disturbance related to harvest and log removal is highly 

dependent on both the equipment used and operator skill. Skidding downhill versus uphill will reduce 

torque and related churning of surface soil. Research by Han-Sup et al. (2005) further supports the use of 

designated and existing skid trails as a way to minimize soil disturbance. Research also indicates that 

compaction does not substantially increase after the second pass of a fully loaded skidder. 

During the summer, soil density and strength increases with the drying of the soil profile, which reduces

equipment impacts. The increase in soil density occurs even on undisturbed soils due to surface sealing. 

During the fall season, rains wet the soil, which reduce soil strength and allows wetting of the soil profile. 

Ground-based yarding in this project would occur primarily when soils are dry (soil moisture is near or 

below the permanent wilting point). The dry soil conditions will limit rutting, soil compaction, and 

displacement and mixing of organic horizons. Harvest of Unit 1 would require ground-based activities 

Alternative Ground-based 

Harvest (Acre)

Ground-based Harvest 

Units (number)

Potential DSD 

(%) 

Potential DSD

(Acre)

1 0 0 0 0 

2 1,044 31 summer, 1 winter 10 104

3 742 19 summer 10 74
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-19

occur during winter conditions to minimize soil disturbances. 

Research in Canada suggests that coarse textured soils with low clay contents may resist compaction 

because aeration pores result from packing together mineral grains (British Columbia Canada 2002). In 

contrast, fine textured soils form pores when mineral particles are aggregated together. These pores are 

easily compressed because there is little resistance from mineral grains. Thus, moisture levels are critical 

when considering equipment operations. Powers et al. (2004) noted that severe compaction did not 

significantly reduce vegetative productivity on sites in the Sierra Nevada and Southern Coastal Plain. 

Planted tree productivity actually increased on severely compacted soils. Gomez et al. (2002) found that on 

sandy soils severe compaction actually increased water holding capacity. The severe compaction increased 

the number of days that water was available for uptake from 45 days to 131 days. The water holding 

capacity was increased in the sandy loam soils by altering the soil physical structure to create more fine

pores for water storage.

Most of the project area is comprised of coarse textured soils, primarily sandy loams, derived from 

decomposed granite with less than 15 percent clay. However, there are inclusions of volcanic rock and 

glacial deposits that have higher clay contents (greater than 20 percent) such as in Units 1 and 3. 

Compaction from past harvest in these units is still strongly present in these clay soil inclusions.

Ground-Based Thinning on Terraced Units

Ponderosa pines are commercial size on some of the terraced units. These terraced plantations will require 

thinning to improve stand health and resilience (Silviculture section 3.2). Commercially thinning and 

yarding these units would require ground-based equipment where slope gradients are less than 35%. 

Protection of the soil surface will be required during ground-based operations to prevent displacement of 

accumulated soil surface organics on terrace benches. Protection may involve yarding on slash mats to 

minimize displacement. New compaction from proposed ground-based yarding would not be a concern 

because of the existing levels of soil compaction. Compaction has been measured to depths of 18 inches on 

terrace benches. 

Ground-based thinning operations will be required to leave 10 to 15 tons/acre of woody debris on the 

terrace benches for soil rehabilitation. This may require some limbing and leaving tops in these units. 

Coarse woody debris levels on the risers between benches should adhere to guidelines in Table 3.5-5. 

Increased woody debris on the terrace benches will increase soil moisture and improve soil biological 

activity, which will also accelerate natural soil recovery processes to alleviate compaction. 

Alternatives 2 and 3 propose up to19 acres of ground-based commercial thinning on terraced units. These 

ground-based terrace units provide opportunities for soil decompaction treatments. Soil decompaction on 

terrace benches is discussed on page 3.5-28. 

Recommendations to Minimize DSD from Ground-based Activities

Elevated levels of legacy soil compaction are present in units 1, 3, and 12. Old skid trails will be used to 

the extent feasible to minimize additional DSD. However, new skid trails may be required in areas where 

the existing skid trail network does not fit current operations. Rehabilitation of soil compaction will be 

accomplished in units 3 and 12 where historic skid trails are suited to soil de-compaction. Specific soil 

protections for Unit 1 are detailed in the following section. All new skid trails and reused historic skid 

trails in summer ground-based units will also be de-compacted upon completion of yarding if soils are 

suitable for de-compaction treatments. The soil rehabilitation effects may not be immediately apparent, as 

it will take several years for diverse native vegetation to establish in areas that previously had limited 

rooting capacity. Disturbed soil organic layers, which play an important role in soil nutrient cycling and 

microbial population/function, will also take time to rebuild after rehabilitation treatments. The importance 

of the rehabilitation cannot be overlooked because it does not immediately restore soils to pre-disturbance 

condition. The rehabilitation provides the critical bridge that allows these natural processes to improve 

conditions over time.
Affected Environment & Environmental Consequences - Soils

3.5-20 Lower West Fork Project Final EIS

The commercial thinning activities are expected to create DSD and reduce soil productivity on temporary 

roads, skid trails, landings, and burn piles. However, this reduction in soil productivity is not permanent or 

irreversible. Natural recovery of previously disturbed areas, albeit slow, has been noted in activity units 

with legacy soil disturbance. Rehabilitation treatments of landings, skid trails, temporary roads, and burn 

piles will greatly speed recovery and improve soil productivity in the long-term (more than 10 years). 

Mitigations (Chapter 2, Section 2.3) and BMPs (Appendix A) are prescribed to limit the severity of any soil 

damage or its areal extent. 

Similar to ground-based operations, skyline, and Tracked Line Machine (TLM) operations will be required 

to leave 10 to 15 tons/acre of coarse woody debris in the terrace units so it can be placed on the benches 

during soil rehabilitation activities. This may require some limbing and leaving tops in these units. Coarse 

woody debris levels on the risers should adhere to guidelines displayed in Table 3.5-5. 

Commercial thin units 1, 3, and 12 with existing DSD levels near or exceeding the Region 1 standards and 

guidelines will require rehabilitation in addition to the standard commercial thinning mitigation measures. 

A net improvement in soil productivity is expected in these units after treatment. 

In Alternative 2, ground-based yarding on 65 acres in Unit 1, below NFSR 363, will occur during winter to 

minimize additional soil disturbance. We estimate that winter ground-based yarding creates less than one 

percent DSD. Unit 1 soils have high coarse fragment content and subsoiling is not feasible on these types 

of soils. The winter yarding will follow standard winter timber operating procedures. Commercial 

thinning operations will be required to limb and leave tops in this area. Woody debris levels should range 

from 15 to 20 tons/acre following thinning to enhance natural soil rehabilitation. No ground-based harvest 

will occur during summer in this 65-acre area of the unit. 

Specific Protections for Unit 1 (65 acres below NFSR 363)

In Alternative 3, we propose an alternate fuels and soils treatment in the 65 acres below NFSR 363 in Unit 

1. Proposed activities for the remainder of the Unit 1 would not change. The alternate treatment would 

involve hand slashing of non-commercial trees. The slash would be left on the ground for one year to 

allow for nutrient leaching into the soils (Palviainen et al. 2004; Baker et al. 1989). At least one year after 

slashing, fuel loads would be reduced with an underburn. Following the underburn, coarse woody debris 

levels would be assessed and additional trees (8 inch DBH and greater) would be felled to meet 15 to 20 

tons of coarse woody debris needed for soil rehabilitation and also create adequate spacing for silvicultural 

objectives. Larger trees would be felled and left on site with an emphasis on retaining the large ponderosa 

pine. Douglas-fir logs greater than 17 inches diameter and longer than six feet are preferred as coarse 

woody debris because Douglas-fir decays at a slower rate than ponderosa pine and would stay on the soil 

surface longer. There may be need for some dispersal of branches to spread out fuels. If the fine fuel load 

is too high, the excess limbs and tops would be hand piled and burned. This alternate treatment would not 

use ground-based equipment and would prevent additional DSD in the 65 acres of Unit 1. 

Summer Conventional Skyline Yarding

Conventional skyline yarding is proposed on commercial thinning units with slopes that exceed 35 percent 

and are too steep for ground-based yarding. Conventional skyline yarding will be used in units where logs 

can be skyline yarded directly to an existing road. TLM yarding will be used in locations where logs 

cannot be yarded directly to a road system. TLM yarding is discussed in the TLM Yarding section below. 

Skyline yarding systems may involve feller/buncher operations to mechanically fall and bundle the trees 

prior to yarding. The feller/buncher operation improves logging efficiency and economics, especially when 

working with small diameter trees. Calculations of DSD in Table 3.5-7 show an increase of 3 percent for 

conventional skyline to existing road systems plus an additional 2 percent increase for feller/buncher 

operations – totaling 5 percent. 

Tracked Line Machine Yarding

TLM yarding is similar to conventional skyline yarding except the skyline system is attached to an 

excavator. The excavator is capable of traveling off the road system and can setup in locations that are 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-21

normally difficult to access. Logs are collected to a temporary landing site and are then yarded by a 

skidder to the road system. The skid trail between the tracked line machine and the road system is referred 

to as a swing trail or a TLM trail. The majority of DSD created during TLM operations is associated with 

the swing trails. Similar to conventional skyline yarding the TLM yarding units may involve feller/buncher 

operations to mechanically fall and bundle the trees prior to yarding. Calculations of DSD in Table 3.5-7 

show an increase of 6 percent for TLM yarding with swing trails plus an additional 2 percent increase for 

feller/buncher operations – totaling 8 percent DSD. 

Table 3.5-7: Summary of Conventional Skyline Yarding and Tracked Line Machine 

Yarding and Potential DSD for each Alternative

Understanding Soil Disturbances from Conventional Skyline Yarding and Tracked Line Machine

Yarding 

Research and monitoring shows conventional summer skyline logging typically causes from three to10 

percent detrimental soil damage (McIver 1998; Clayton 1981; McIver and Starr 2001). Monitoring 

following salvage logging in the Bitterroot NF after the fires of 2000, found little DSD in conventional 

summer skyline yarding units (Forest Plan Monitoring and Evaluation 2006). In addition, monitoring 

found mitigation measures employed in the corridors were effective at limiting offsite erosion (no erosion, 

rill, or gully formation was noted in the corridors). Loss of organic matter and ground cover was minimal

(BAR timber sale unit logs, 2001-2004, available for review at Forest Supervisor’s Office). Monitoring of 

skyline-yarded timber sales on the Bitterroot NF indicates that DSD did not occur in the absence of tractor 

swing (Forest Plan Monitoring and Evaluation 2006). However, summer skyline yarding combined with 

summer tractor swing detrimentally disturbed two to nine percent of the unit. Bitterroot NF monitoring 

data was used to calculate DSD in this project. Conventional skyline yarding to landings on the existing 

road system is estimated to create an average three percent DSD within units. Units yarded with TLM will 

require tractor swing. TLM yarded units with tractor swing are estimated to create an average six percent 

DSD within the overall proposed treatment area (harvest unit).

Soil disturbance occurs when moving trees to and within the corridor. These corridors are narrower than 

skid trails caused by ground-based equipment with an average spacing of 100 feet. In this situation, 

corridors comprise approximately three percent of the unit. Conventional skyline logging soil disturbance 

may be greatest at the landing where logs are no longer suspended and corridors converge. These effects 

and the risks of soil erosion can be minimized by ensuring good suspension of the log and avoiding wet soil 

conditions. Soil SWCPs for summer skyline yarding include construction of waterbars (covered under 

timber sale contract clauses) and covering bare soil areas with slash where the timber sale administrator 

identifies the need. Conventional skyline and TLM yarding should also be completed during dry soil 

conditions to minimize soil disturbance. 

The use of a feller/buncher machine is proposed on the conventional skyline and TLM units to improve 

efficiency for falling and bundling of logs for skyline yarding. Currently the Bitterroot NF does not have 

forest-specific monitoring data as a basis for estimating soils effects. However, the Bitterroot NF soil 

scientist has observed this equipment and yarding strategy on private lands near Philipsburg, MT, and 

estimated detrimental soils effects at approximately two percent. The Flathead NF has also completed 

conventional skyline harvest in combination with feller/buncher equipment on several harvest units. 

Monitoring of these units indicates that overall DSD averaged approximately five percent, with two percent 

attributed to the feller/buncher operations. On the Bitterroot NF, monitoring of conventional skyline 

harvest units indicates that DSD typically averages three percent and TLM yarding with tractor swing 

averages six percent. An estimation of two percent DSD for feller/buncher operations in combination with 

Alternative Conventional 

Skyline (Acre) TLM (Acre) (# of Units) Potential DSD(%)

Potential DSD 

(Acre)

1 0 0 0 0 

2 1,094 356 38 3-8 79

3 813 146 22 3-8 71
Affected Environment & Environmental Consequences - Soils

3.5-22 Lower West Fork Project Final EIS

conventional skyline and TLM on the Bitterroot NF would total five and eight percent DSD respectively. 

Mechanical felling and bundling was proposed as a pilot study in the Trapper Bunkhouse project area 

(Trapper Bunkhouse FEIS). Results from the pilot project will be used to assess the feasibility of these 

operations and verify soils impacts. If the pilot project indicates DSD exceeds the estimated two percent, 

we will not use this equipment and strategy on Lower West Fork units but will revert to conventional 

felling and skyline yarding systems.

Conventional Skyline and Tracked Line Machine Yarding on Terraced Units

Terrace units that have commercial value and slopes greater than 35 percent would be yarded with 

conventional skyline or TLM. Slope gradient should provide appropriate deflection of logs over the terrace 

benches. Trees will be hand felled to minimize disturbances on these steep terrace units. The thinning of 

skyline units would follow silvicultural prescriptions in Section 3.2. 

Alternatives 2 and 3 propose conventional skyline and TLM based commercial thinning on a maximum of

254 acres of terraced units. Soils would be rehabilitated as detailed in the Soil Rehabilitation Treatments – 

Mitigations and Opportunities section.

Recommendations to Minimize DSD from Skyline Activities

Most of the DSD noted during skyline operations is in units where TLM yarding and tractor swing occurs. 

The swing trails would be rehabilitated where soil conditions are appropriate. The rehabilitation would 

lower compaction levels and provide erosion control. The rehabilitation of new skid trails would also 

reduce detrimental soil conditions in the tractor swing areas. All conventional skyline and TLM units have 

slopes greater than 35 percent, which increases the risk of erosion. SWCPs for skyline operations will be 

implemented to reduce loss of groundcover and minimize the risk of soil erosion (Chapter 2.6). Erosion 

control measures will be applied in skyline corridors where mineral soils are exposed. Soil SWCPs for 

summer skyline yarding include partial suspension of the logs and construction of waterbars, which are 

covered under timber sale contract provisions. In addition, the timber sale administrator will identify areas 

of bare soil in the corridors that require covering with slash. Conventional skyline and TLM yarding 

should also occur during dry soil conditions to minimize soil disturbance. 

Duration of Harvest Effects

Researchers have found that soil compaction generally lasts 20 to 40 years depending on soil texture 

(Simcock et al. 2006; Powers et al. 2004; Powers et al. 2005; Froehlich et al. 1983, Wert and Thomas, 

1981). Surface layers, several centimeters thick, recovered faster than the subsurface layers, and 

monitoring in the project area has shown similar results. A variety of physical and biological processes

promotes the recovery of soil compaction. Physical processes include freeze-thaw and wetting-drying 

cycles. Both of these processes would be site specific, for example, soils would need to contain swelling 

clay particles for wetting-drying cycles to remediate soil compaction. Biological recovery includes the role 

of roots and organisms. Recovery of surface soil organic matter displaced during logging activities is also 

a long process and takes 20 to 60 years for raw soil organic matter to decompose into humus (Hungerford 

1995; Powers et al. 2004). 

Though recovery timelines for both physical soil properties (i.e. de-compaction and aggregate formation) 

and organic matter with humus and top soil formation are long, the Lower West Fork project will not 

change the natural processes of recovery. Vegetation, organic matter, ground cover, and hydrologic 

function will be preserved on all but the landings and heavily used skid trails. Rehabilitation treatments 

and application of BMPs and SWCPs will limit physical soil disturbance and accelerate natural soil 

rehabilitation processes. This project will not cause irreversible changes to soil structure or organic matter 

over time. Subsoiling treatments on skid trails used in this project will advance the natural soil recovery 

process.

Non-commercial Thinning

Non-commercial thinning is proposed in both action alternatives. Non-commercial thinning will occur in 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-23

portions of the commercial thin units where stocking levels are high but trees have not reached commercial 

size. In both Alternative 2 and Alternative 3, 16 units covering 296 acres are proposed for non-commercial 

thins. The non-commercial thin units would be thinned by hand crews without the use of ground-based 

equipment. The non-commercial thinning activity would not affect soil productivity. All work would be 

accomplished with hand tools, thus there would not be soil compaction or other detrimental changes in the 

soil physical properties and no loss of nutrients. The Forest Soil Scientist field reviewed the noncommercial thin units in Alternatives 2 and 3. 

Prescribed fire would not be used in units with slash levels less than 10-15 tons/acre. Slash that exceeds 

10-15 tons/acre may be piled and burned. There may be units where slash levels of 10 to 15 tons/acre 

create fuel load concerns. These units will be reviewed following thinning to determine the need for piling 

and burning. If piling and burning is needed, slash would be left on site for at least one year before piling 

to allow the release of nutrients into the soil and provide fine organic matter for soil development. 

Hand Piling and Burning (Not Associated with Landings) 

Hand piling and burning may occur in combination with other treatments including commercial thins, noncommercial thins, and prescribed burns. Hand piling and burning is proposed on 552 acres in Alternative 

2, and 357 acres in Alternative 3. Hand piling refers to piling of slash inside treatment units and not the 

large slash piles that accumulate during yarding operations. 

Hand piling and burning is not anticipated to have adverse effects on soil productivity. Burning of large 

slash piles may sterilize the underlying soil because heat is retained in the pile. The intense heating may 

cause localized soil sterilization, reduced water infiltration, and reduction in groundcover. In order to 

prevent these soil impacts, pile sizes will be limited to less than about 50 square feet (average pile size 

would be 6-8 feet in diameter). Piling and burning of slash on previously disturbed sites is recommended 

to minimize soil disturbance. 

Small pile sizes may prevent the complete consumption of organic horizons and intense heating of the soil. 

Burning of piles during moist conditions may also reduce the chances of consuming organic matter and 

intense soil heating. However, even in cases of complete organic matter consumption beneath the piles, 

these disturbances would not be considered DSD since continuous loss of surface cover would not exceed 

100 square feet at each pile location. These treatments would not create DSD and would meet the R1 soil 

quality guidelines for the action alternatives. 

Maintenance Burning and Prescribed Fire 

The effects of this treatment would be similar to low severity fires that reduce fuels while not killing most 

of the live trees, shrubs, and other forest vegetation. Underburning, broadcast burns, or other types of 

prescribed fire are proposed on 4,497 acres in Alternative 2, and 3,031 acres in Alternative 3. Burning in 

spring would reduce effects caused by high soil heating such as loss of nutrients through volatilization 

(DeBano et al. 1999). Soil organisms necessary to recycle nutrients would be available on the burned sites. 

Ideal soil conditions for maintenance and prescribed burns typically occur in the spring or fall. 

Nitrosomas sp. bacteria and fungi are relatively sensitive to soil temperatures encountered in light to 

moderate severity fires whereas sulfur, soil structure, soil wettability, nitrogen, and organic matter are only 

moderately sensitive (DeBano et al. 1999). The risks to soil organism’s decreases when soil moisture 

content is less than 15 percent (dry soil) and the duration of the heat is less than 30 minutes. Conversely, 

the potential for nitrogen loss and infiltration loss increases in dry soils.

Upon completion of maintenance burning or other prescribed fire activities, at least 70 percent ground 

cover is necessary to prevent detrimental accelerated erosion and loss in soil productivity. Mitigation for 

this project will assure that in those cases where ground cover is less than 70 percent prior to burning, 

consumption and loss of ground cover should not exceed 15 percent. Ground cover includes duff, organic 

soil horizons, basal area of vegetation, fine woody debris, coarse woody debris, and surface coarse rock 

fragments. The soil scientist will be consulted prior to burning to ensure soil conditions are acceptable for 
Affected Environment & Environmental Consequences - Soils

3.5-24 Lower West Fork Project Final EIS

burning (Chapter 2, Section 2.3). 

Coarse woody debris (CWD) requirements must also be considered where prescribed fire is used. 

Mitigations will assure that prescribed fire operations will attempt to minimize the loss of CWD needed for 

soil development. In fuel reduction areas where CWD is nearing the low threshold levels, CWD would not 

be ignited intentionally during hand lighting operations. Prescribed fire can be used in these areas to recruit 

additional CWD through burn mortality. Burning prescriptions will be written and carefully implemented 

to take these, as well as other resource limitations, into consideration. These treatments would not create 

DSD and would meet the Region 1 standards and guidelines for all action alternatives. The Forest Soil 

Scientist reviewed these burning units in the field.

Lopping and Scattering 

Small, non-merchantable material will be lopped and scattered in the commercial thin units. This treatment

will mitigate the loss of nutrients from whole-tree yarding and will add coarse and fine woody material to 

the site. No negative effects to soils will result from this prescription. The Forest Soil Scientist reviewed 

these proposed activities in conjunction with other treatments (primarily commercial thinning units) in the 

field. 

Landing Construction and Use

Landings would be associated with each commercial thin unit. Frequent, small, roadside landings would be 

used for the skyline and ground-based operations. These landings would be located on the edge of existing 

system roads and would generally be within the road right-of-way. For planning purposes, we estimate the 

needed landings would each cover approximately 1⁄4 - 1⁄2 acre. Landings associated with system roads are 

considered part of the Bitterroot NF transportation system.

In many cases, large slash piles will accumulate at the landings from the whole tree yarding systems. 

These slash piles will be burned after they have dried thoroughly (typically 1 – 2 years). Burning will 

occur on the landing areas to reduce further soil impacts outside of the transportation system.

Temporary Road Construction and Rehabilitation 

An estimated 2.2 miles of temporary road construction would be required for Alternative 2 and 1.5 miles 

for Alternative 3. Temporary road construction will include the construction of new road and the opening 

of old roads that are no longer included in the forest road inventory. 

Road templates exist for historic roads, and in most cases, these roads require minimal construction to 

improve them for hauling. Vegetation removal and drainage improvements are the typical construction 

needed on these roads. Soil disturbances associated with opening these roads will be minimal since they 

were detrimentally disturbed when the roads were initially constructed. 

New temporary road construction for each unit will not exceed 3⁄4 mile in the action alternatives. Soil 

disturbance from temporary road construction is considered detrimental for the purpose of DSD 

calculations in this analysis. Temporary road disturbances are considered DSD even after rehabilitation 

activities are completed. The detrimental soil conditions from temporary roads may reduce soil 

productivity for several decades until vegetation, organic matter, and hydrologic function are restored. 

Rehabilitation of temporary roads speeds the process of vegetation and hydrologic recovery and alleviates 

detrimental conditions over time. By rehabilitating the roads, detrimental soil conditions will not persist or 

become a permanent loss of soil productivity. Table 3.5-8 displays the miles of temporary road 

construction and acres of associated DSD. 

Table 3.5-8: Temporary Roads and Potential DSD for each Alternative

Alternative Temporary Roads

(Miles)

DSD based on 25 ft road base

(Acres)

1 0 0

2 2.2 6.6

3 1.5 4.6
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-25

Assuming average road prism width is 25 feet, approximately 6.6 acres of land would be affected in 

Alternative 2 and 4.6 acres in Alternative 3. These acreage calculations include the re-opening of historic 

roads in addition to new temporary road construction.

All temporary roads would be rehabilitated following use as part of the timber sale or stewardship contract. 

Rehabilitation activities on new temporary road construction would include recontouring, slashing, and 

seeding (Chapter 2, Section 2.3). Historic roads will be stabilized by removing drainage structures; ripping, 

seeding, and fertilizing the roadbed; and closing the entrance to these roads. 

Herbicide Application

Herbicide analysis completed in the Selway-Bitterroot Weeds Draft EIS, March 2008, has been used to 

assess herbicide effects on soils for the Lower West Fork Project. Herbicide application would occur only 

in Alternative 2. No more than 1,400 acres of herbicide treatment would occur during the life of the 

project. Herbicide treatments are proposed in combination with rehabilitation treatments to reduce 

competition from noxious weeds and improve the conditions for native plant establishment. Herbicide 

treatments in Alternate 2 would be applied in selected treatment units such as terrace rehabilitation, road

decommissioning, temporary road obliteration, and the rehabilitation of major skid trails, tracked line 

machine and swing trails, and landings.

There are no long-term direct effects on soil physical properties or productivity from herbicide treatments. 

Herbicides used for weed control, even in steeper terrains, do not disturb soils and maintain hydrologic 

conditions. Indirectly, the elimination of weeds could increase areas of bare ground, resulting in increased 

soil erosion for the short-term (1 to 3 years). For the long-term, however, application of herbicides would 

reduce the density of invasive weeds and promote native vegetation recovery, restore surface protection, 

and provide erosion control benefits. Herbicides encourage grasses by the selective pressure on broadleaf 

species. Since grasses have better soil-binding characteristics than the target broadleaf species, herbicide 

treatment would improve soil stability on the treated sites. 

Another indirect outcome of herbicide use is the persistence of the chemical in the soil. All the herbicides 

analyzed for this project have some soil activity; that is, they dissolve to some extent in water and

susceptible plants can readily absorbed them from soil moisture. These herbicides can move with water as 

it moves through soil. Although these herbicides are all water-soluble and soil active to some extent, they 

vary greatly in their environmental persistence (Table 3.5-9). Persistence can be a benefit in restoration 

efforts because it provides more time for some native grasses and broadleaf plant species to become 

established before noxious weeds re-invade. Target weed species all produce many seeds that remain 

viable in the soil for long periods.

Table 3.5-9: Herbicide Characteristics in Soils 

Chemical Evaluated Soil Half Life (Days) Sorption Coefficient

(Soil Koc)

Herbicide Movement 

Rating

Aminopyralid 103 1.05-24.3 Moderate

Chlorsulfuron 40 13-54 High

Clopyralid 40 6 Very High

Dicamba 7-90 2 Very High

Glyphosate Rodeo 47 24,000 Very Low

Imazapic 7-150 112 Moderate

Imazapyr 25-141 9 Moderate

Metsulfuron Methyl 30-120 35 High

Picloram 90-513 16 Very High

Sulfometuron methyl 15-33 61-122 Moderate

Triclopyr -TEA 30-46 20 Moderate

2,4-D Amine 10 100 Moderate
Affected Environment & Environmental Consequences - Soils

3.5-26 Lower West Fork Project Final EIS

Since these chemicals can move with water, we must consider the permeability and water-holding capacity 

of the soil. These properties determine how much water moves through the soil into ground or surface 

water after rainfall. If the soil retains a large quantity of water in its upper horizons for later use by plants, 

the water and partially dissolved herbicide would have little opportunity to move. In contrast, if a soil is 

highly permeable and has little water-holding capacity, moisture passes through the soil rapidly and carries 

some of the herbicide with it.

Soil adsorption coefficient (Koc) is an index of the herbicide mobility. The larger the Koc, the more 

strongly the herbicide is held to soil organic matter and the less likely it will leach. Of the herbicides 

proposed for treatment, glyphosate is the least likely to leach with a Koc of 24,000 and dicamba would 

leach rapidly with a Koc of two (Table 3.5-9). Other popular herbicides such as Clopyralid (6) and 

Picloram (16) are also highly susceptible to leaching.

Soil half-life is the period of time it takes for one-half of the herbicide in the soil to degrade (see Table 3.5-

9). Each half-life that passes reduces the amount of herbicide present in the soil by one-half. Half-life can 

vary due to soil microbial populations, soil moisture, soil temperature and other factors. Non-persistent 

herbicide would have a half-life of 30 days or less. Persistent herbicides have a half-life of greater than 100 

days. On average, all proposed herbicides have a moderate persistence. Picloram had the longest reported 

half-life, up to 513 days, and did not degrade overtime (USDI-EPA 1995a). 

Picloram, with 2,4-D, applied separately and in combination, did not accumulate in sandy and sandy loam 

soils on two sites in North Dakota after four years of applications throughout a depth profile up to four feet 

(Lym 1986). The 2,4-D applications occurred biannually, totaling eight applications. Soils on these sites 

have similar coarse-grained permeability characteristics to the soils in the project area. Fryer (1979) 

showed that picloram residue from three years of applications in a sandy loam soil environment 

disappeared below 30 cm about 16 months after the last application. 

Picloram is water soluble, mobile in sandy soils low in organic matter, and may affect desirable plants that 

have roots growing in treated areas. Degradation by soil microorganisms is slow, and primary breakdown 

is by ultraviolet light. Picloram is relatively persistent, although its persistence varies with soil type and 

weather. The mobility and persistence of picloram has generated concerns over possible groundwater 

contamination or runoff to surface water if applied contrary to label instructions. Because of this concern, 

picloram is unsuitable for use on areas with shallow water tables or in riparian areas, and is restricted from 

use near surface water or groundwater.

Research on a grassland site in Missoula County found no picloram below 20 inches soil depth (Watson et 

al. 1989). The minimum detection limit in this study was 10 parts per billion. On a forested site with 

coarser soils and precipitation rates more comparable to sites analyzed here, this study found picloram 

levels ranging from 206 to 366 parts per billion in the upper 5 inches of soil after an application of 1 pound 

of picloram per acre. A maximum concentration of 24 parts per billion was detected at soil depths between

30 and 40 inches. No picloram was measured in shallow groundwater wells with a detection limit of 0.5 

parts per billion. 

Results reported by Scifres (1977) showed that 2,4-D and dicamba are less persistent than picloram. 

Residues of dicamba in the soil usually occur no deeper than 3 to 4 feet following application and 

dissipated after 2 to 4 months. Residue of 2,4-D was found closer to the surface and dissipated within days. 

Picloram, which is decomposed by microorganisms, may persist for a year after application at rates of 1 

lb/acre.

Additional studies of the movement and persistence of herbicides in soil at several sites in western Montana 

are ongoing. These studies include comparisons of picloram, 2,4-D, and clopyralid. Picloram has been 

shown to be mobile under field conditions. In Montana, picloram was applied at half the maximum label 

rate (1 pound/acre), and was detectable 790 days after application in the 48 to 60 inch soil layer (soil with 

2.2% organic matter; USDI-EPA 1995). 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-27

In the EPA Re-registration Eligibility Decision (RED) for picloram, the agency was concerned with ground 

water contamination and risk to endangered species. Data currently available to the EPA indicates that 10 

states detected picloram concentrations up to 30 parts per billion in groundwater. Once in groundwater the 

chemical is unlikely to degrade even over a period of several years (USDI-EPA 1995a, 1995b). The levels 

detected were below the lethal concentrations for rainbow or cutthroat trout. 

We expect herbicides would have a short-term effect to soil productivity based on the persistence in soil, 

soil half-life, and the possibility of repeat application. Long-term soil productivity would be maintained in 

compliance with Region 1 standards and guidelines. 

Herbicides could also cause temporary reductions in biodiversity and relative biomass of individual species 

of macro- and micro-organisms in soil due to chemical loading. These effects, however, are not expected 

to persist under the proposed herbicide application frequency because the negative effects are temporary 

and the populations generally recover after a few days or weeks.

The following BMPs (Appendix A) and project design measures (Chapter 2) would be applied to minimize 

herbicide effects on soil productivity and soil organisms: 

Ø picloram would not be applied directly to water or within 50 feet of streams or water 

Ø the maximum picloram application rate would be 1.0 pound/acre and spot treatment would be no 

larger than 50% of an acre (USDI-EPA 1995a) and this will occur only in uncommon instances 

where new, small infestations of Dalmation toadflax, leafy spurge, rush skeletonweed, or other 

difficult to eradicate species are found in the project area

Ø mixing, storage, and transportation of all herbicides would be controlled 

Ø no 2,4-D amine (ester formulation) or triclopyr-BEE would be applied 

Herbicide treatments would reduce noxious weed competition so native plant communities re-establish and 

increase plant diversity. This would maintain and promote long-term soil quality and stability. 

Soil conditions in the project area have been degraded by past harvest activities from ground-based 

skidding, site preparation, and terracing. Compaction is still evident on historic skid trails in several 

proposed commercial thin units and along terrace benches. Subsoiling and slashing would occur in 

commercial thin units with historic skid trail compaction. Summer skid trails used in the current entry will 

also be subsoiled where root-limiting compaction is present. Soil compaction will be reduced and native 

plants will be re-established on terrace units to improve soil conditions and prevent noxious weed spread. 

Soil Rehabilitation Treatments – Mitigation and Opportunities

Need for Soil Rehabilitation

Subsoiling breaks up compaction at depth and improves soil aeration and hydrologic function. Subsoiling 

and other methods involving ripping, break up the soil mass to promote the infiltration and flow of air and 

water through the soil matrix (Andrus and Froehlich 1983, and Luce 1997). However, ripping methods can 

cause surface disturbance and mixing of subsoil with organic and topsoil horizons. Subsoiling initiates soil 

restoration by enabling soil organisms and plants to penetrate compacted soil layers. Plants and soil 

organisms continue to modify soil structure and chemistry and naturally restore soil processes. Initiating 

these physical and biological processes through subsoiling, accelerates soil and site condition improvement, 

and achieves the soil quality guidelines. 

A decompaction study of forested soils in Oregon indicates that tilled soils average bulk densities similar to 

undisturbed soil (Heninger, et. al., 2002). The study indicated that the tillage was effective at recovering 

the undisturbed soil productivity potential for timber height and volume growth on the disturbed sites. 

Work and research in Canada has shown that soil restoration techniques, when prescribed on a site-specific 

basis, are effective in reducing the effects of equipment use on the soil resource (Bulmer, 1998, Pgs.13-21). 

In order for subsoiling techniques to be effective, soil texture, soil moisture, organic matter content, and 

erosion potentials must be considered (Plotnikoff et al. 2002). Additional findings from the work in 
Affected Environment & Environmental Consequences - Soils

3.5-28 Lower West Fork Project Final EIS

Canada suggest that tillage, under appropriate soil moisture conditions, effectively decompacted landings 

constructed on medium-textured soils. 

Most of the soils across the ground-based units in the Lower West Fork Project area are primarily medium 

to coarse textured and should be well suited for subsoiling activities. The historic skid trails have 

continuous and heavily compacted soils. Kreger and Bliss (1993) found that to effectively decompact soils, 

they needed to be heavily compacted and the compaction continuous. Research has also shown that 

decompaction of fine-textured soils is difficult because field operations need to coincide with optimum soil 

moisture conditions. Subsoiling significantly reduced the soil bulk density on heavily used landings in 

British Columbia (Carr 1989). The overall reduction of bulk density was dependent on soil texture, with 

coarser soils showing the greatest improvements in bulk density. 

Subsoiling also has positive effects on soil biota. A study by Otrosina, Sung, and White (1996) indicated 

that subsoiled plots had increased fungal biomass when compared to compacted thinning plots and 

undisturbed control plots. The study was completed in the Sierra Nevada Range in California. Sampling 

sites were on loam/clay loam soils and on granitic soils with coarse sandy loam texture, similar to those 

found in the Idaho batholith on the Bitterroot NF. The study noted that subsoiling increased the production 

of fine root biomass, which contains significantly higher amounts of mycorrhizae than soil alone (Sung et 

al. 1995). 

Use of Proper Equipment is Key to Decompaction Success

There are several methods and types of machinery for subsoiling applications. The subsoiling proposed in 

this project would be completed with a subsoiling grapple rake (SGR) which is an attachment used on an 

excavator. The excavator operator has more control of the SGR than subsoiling equipment towed behind a 

dozer. The SGR enables the operator to reduce the amount of soil plowing and churning that sometimes 

occurs with other equipment. Subsoiling done correctly does not mix soil horizons, instead the curved 

shank and winged tooth work together to shatter compaction at depth. Soil mixing may occur if the shank 

is not lifted quickly enough when encountering roots, large rocks, or buried logs. Use of the SGR will 

minimize this problem because the operator is capable of recognizing the problem before the soils are 

mixed. The operator controlling the SGR feels the resistance of roots and rocks while handling the 

equipment controls and can quickly stop the activity and replace the shank around the buried objects. This 

may not always be the case with subsoiling equipment towed behind a dozer, which is why that method 

will not be used for this project.

Effectiveness of SGR Treatment on the Bitterroot NF

Subsoiling with the SGR was monitored in the Hayes Creek area on the Bitterroot NF in 2008. The 

subsoiling monitoring involved digging soil pits in subsoiled areas and in adjacent compacted soils to note 

differences in the soil characteristics. Soil pit observations in the subsoiled areas indicate the entire soil 

profile was decompacted and soil moisture infiltration increased. Soil moisture was four to 40 percent

greater in the subsoiled areas compared to adjacent compacted sites. Monitoring also indicates that soil 

horizons were intact and not mixed. Surface organics and vegetation were not detrimentally disturbed. 

Vegetation growth was more prolific on the subsoil sites from increased infiltration and moisture in the 

rehabilitated soils. The increased vegetative biomass on the subsoil sites will in turn build organic horizons 

more quickly than the compacted soils – another benefit of the decompaction. Spotted knapweed was 

abundant in several of the monitoring locations before subsoiling in 2008. Recent monitoring indicates that 

subsoiled areas do not have more knapweed compared to adjacent compacted areas. The grasses were 

more prolific on the subsoiled areas, which over time may out-compete and reduce the knapweed 

population. Additional time will be required to note changes in vegetation from subsoiling at the Hayes 

Creek site since only one year of recovery has been monitored (SOILS-011). 

Soil Rehabilitation on Skid Trails 

Subsoiling with a SGR will occur on all skid trails used for yarding in the proposed summer ground-based 

units and in TLM units where tractor swing is required. Timber will be yarded using historic skid trails 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-29

where feasible in the action alternatives. The majority of subsoiling rehabilitation would occur on these 

previously disturbed areas. The rehabilitation of compacted soils on reused skid trails would lead to a net 

improvement of soil productivity on those units with existing soil disturbance. 

The actual reduction in DSD depends on the amount of historic skid trails used and rehabilitated in a given 

unit. The rehabilitation treatments are not expected to reduce historic detrimental soil conditions 

immediately. However, by breaking up subsurface compaction, subsoiling will accelerate natural soil 

recovery processes, such as root penetration, soil microbial activity, water infiltration, and freeze-thaw 

cycles. We anticipate that soils will more closely resemble reference conditions within 5 to 10 years 

(Heninger, et. al. 2002). 

Soil Rehabilitation on Terraced Units 

Soil rehabilitation in the terrace units would focus on terrace benches where soil compaction and surface 

disturbances are the greatest. The majority of terrace units in the project area have steep slopes (> 35%) 

that are not suitable or safe for ground-based equipment necessary to complete active soil decompaction 

treatments with a subsoiler or ripper. As an alternative treatment, vegetation in steep terrace units will be 

hand felled and removed commercially with skyline yarding systems or through hand piling and prescribed 

burning. Vegetation treatments will meet silvicultural prescriptions provided in section 3.2. The 

treatments will be required to leave 10 to 15 tons/acre of woody debris specifically on the terrace benches 

for soil rehabilitation. This may require some limbing and leaving tops in these units. Woody debris levels 

on the risers between benches would adhere to guidelines displayed in Table 3.5-5. Increased woody 

debris on the terrace benches will increase soil moisture and improve soil biological activity, which will 

also accelerate natural soil recovery processes to alleviate compaction. 

In terrace units where slope gradients are less than 35 percent, vegetation may be removed with groundbased yarding systems. Following ground-based yarding the terrace benches may be subsoiled or ripped to 

break up compaction. Ripping may occur on these areas as an alternative to subsoiling due to the high 

amount of soil mixing already present on the terrace benches. In this case, additional soil mixing by 

ripping would not create adverse soil conditions. An organic fertilizer would be applied following 

subsoiling or ripping on the terrace benches to improve soil organic concentrations, nutrient cycling, and 

microbial populations. Woody debris would be placed on terrace benches following these treatments at a 

rate of 10 to 15 tons/acre. The preferred method of revegetating the site is to allow native vegetation 

growing on the risers between the benches to encroach and establish on the benches. However, the Forest 

Service would seed a mixture of native grasses and forbs if weed establishment is probable. The 

establishment of native, understory plants would enhance soil building on the terrace benches and foster 

soil condition improvement over time. 

Mitigation measures designed to protect the soil resource have been summarized here for the following 

activities. All other soil protection measures not discussed here are covered by SWCPs and BMPs, which 

are incorporated into standard timber sale contracts.

Summary of Mitigation Measures

Ø Ground-Based Yarding

• Historic skid trails will be used to the extent feasible in the ground-based units.

• Winter ground-based yarding is required in about 65 acres of Unit 1 below NFSR 363 in 

Alternative 2. Commercial thinning operations will be required to limb and leave tops in this 

area. Woody debris levels should range from 15 to 20 tons/acre on the ground following 

thinning to enhance natural soil rehabilitation. Woody debris will be a mix of fine and coarse 

wood. 

• Winter ground-based yarding:

• The snow depth, distribution, and air temperature conditions must be such that ground-based 
Affected Environment & Environmental Consequences - Soils

3.5-30 Lower West Fork Project Final EIS

operations maintain the following combination of snow depth and frozen soil conditions under

• *Pre-trailing. Pre-trailing selected skid trails a day or so prior to skidding or other heavy trail 

use is a way to achieve this objective. If average, pre-compacted snow depth along the 

proposed trail is more than 15 inches, pre-trailing can be done whether or not the soil is frozen. 

If pre-compacted snow depth is 8 to15 inches; pre-trailing should be done only if the soil is 

solidly frozen in the top one inch or more. Otherwise, pre-trailing should be delayed until 

more snow falls to accumulate to the 8 inch or more depth. To further aid soil protection, pretrailing should be done using an “easy-does-it” approach, including slow ground speeds and 

steady movements. Avoid spinning tires and bouncing equipment around on trails as much as 

possible. Adequate pre-trailing air temperatures generally are in the low 20 ̊ Fahrenheit or 

lower. For more information about pre-trailing conditions, consult with the Forest soil 

scientist.

the wheels or tracks/treads of equipment at all times. (* see below).

• In Alternative 2, ground-based yarding on 65 acres in Unit 1, below NFSR 363, will occur 

during winter to minimize additional soil disturbance. Unit 1 soils have high coarse rock 

fragment content and subsoiling is not feasible without causing additional disturbance. The 

winter yarding will follow standard winter timber operating procedures. Commercial thinning 

operations will be required to limb and leave tops in this area. Woody debris levels should 

range from 15 to 20 tons/acre following thinning to enhance natural soil rehabilitation. 

• Winter operations could be utilized in the majority of ground-based units if winter conditions 

are met (see soil mitigations page 3.5-28 & 29). Units 3 and 12 will require subsoiling of 

historic skid trails even if winter ground-based operations are utilized in order to create a net 

improvement in soil productivity in these units. 

• In Alternative 3, an alternate method is proposed to treat fuels and soils in the 65 acres below 

NFSR 363 in Unit 1. Proposed activities for the remainder of the Unit 1 would not change in 

Alternative 3. The alternate treatment would involve hand slashing of pre-commercial 

materials. The slash would be left on the ground for one year to allow nutrients to leach into 

the soils (Palviainen et al. 2004; Baker et al. 1989). At least one year after slashing, fine fuel 

loads would be reduced with a prescribed underburn. Following the underburn, coarse woody 

debris levels would be assessed and additional trees (8 inch dbh and greater) would be felled to 

meet 15 to 20 tons of coarse woody debris needed for soil rehabilitation, as well as, create 

adequate spacing for silvicultural objectives. There may be need for some dispersal of 

branches to spread out fuels. If fine fuel loads increase potential fire intensity, the excess fuels 

would be handpiled and burned. This alternate treatment would not require ground-based 

equipment so additional DSD would not occur in the 65-acre area of Unit 1. 

• Summer ground-based yarding in this project will occur when soils are dry (soil moisture is 

near or below the permanent wilting point). 

Depth of compacted (by equipment) snow 

under wheels or track/tread

Minimum thickness of solidly frozen soil 

needed below compacted snow layer 

10 or more inches 0 inches 

7 to 10 inches 1 inch 

4 to 7 inches 2 inches 

less than 4 inches 4 inches 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-31

• Subsoiling with a SGR (or other excavator mounted subsoiling implement that achieves the 

desired results) will occur on all skid trails used for summer ground-based yarding, both 

historic and new, in the summer ground-based units (this excludes the 65 acres in Unit 1 below 

NFSR 363). When available, slash will be placed on the decompacted skid trails by the SGR. 

Ø Skyline Yarding 

• Subsoiling will occur on all skid trails used for yarding in skyline units where summer, tractor 

swing is required. 

• Mechanical felling and bundling has been proposed as a pilot study in the Trapper Bunkhouse 

project (Trapper Bunkhouse FEIS). Results from the pilot project will be used to assess the 

operation feasibility and assumptions that soil impacts are minimal. If the pilot project 

indicates DSD exceeds two percent, then conventional felling and skyline yarding would occur 

in this project.

Ø Temporary Roads 

• Rehabilitation activities on new temporary road construction would include recontouring, 

slashing, and seeding (Chapter 2, Section 2.3). 

• Historic roads will be stabilized by removing drainage structures; ripping, seeding, and 

fertilizing the roadbed; and closing the entrance to these roads. 

Ø Treatments on Terrace Units

• Mechanical thinning operations will ensure adequate woody debris (fine and coarse wood) is 

left in the units for soil rehabilitation on the terrace benches. Terrace benches will have 10 to 

15 tons/acre of woody debris following thinning and prescribe burning treatments. 

• Prior to any future piling and burning on terrace units, the Forest Soil Scientist will evaluate 

the terrace benches to determine if organic soil horizons have adequately developed following 

thinning and soil rehabilitation. 

Ø Hand Piling and Burning (Not Associated with Landings) 

• Pile sizes will average 6-8 feet in diameter so localized areas of soil disturbances will be less 

than about 50 square feet in size. 

• Pile burning should occur during moist conditions to minimize duff consumption and high 

severity burn impacts on soils. 

• Where feasible, pile and burn slash where DSD already exists, such as on old log landings, skid 

trails, and roads associated with the past harvest units. By piling and burning thinning slash in 

areas where soil disturbance currently exists, no new areas of DSD would result from proposed 

actions. 

Ø Prescribed Fire and Maintenance Burning 

• Upon completion of prescribed fire or maintenance burning, at least 70 percent ground cover is 

necessary to prevent detrimental accelerated erosion and loss of soil productivity. In those 

cases where ground cover is less than 70 percent prior to burning, consumption and loss of 

ground cover should not exceed 15 percent. Ground cover includes duff, organic soil horizons, 

basal area of vegetation, fine woody debris, coarse woody debris, and surface coarse fragments. 

Fire prescriptions will be designed to meet these soil protection requirements.

• CWD larger than 15 inches in diameter will not be intentionally ignited during hand lighting 

operations. However, once hand crews light the fire, the fire may burn into large CWD and 
Affected Environment & Environmental Consequences - Soils

3.5-32 Lower West Fork Project Final EIS

combust various pieces.

• Allow time for nutrients to leach from slash prior to burning. The slash will be left through 

one winter after cutting to allow for initial decomposition and nutrient leaching. 

Ø Herbicide Application 

• Picloram would not be applied directly to water or within 50 feet of streams or water. 

• The maximum application rate of picloram would be 1.0 pound/acre and spot treatment would 

be no larger than 1⁄2 an acre (USDI-EPA 1995a). The use of the maximum allowable picloram 

rate will occur only in uncommon instances where new, small infestations of Dalmation 

toadflax, leafy spurge, rush skeletonweed, or other species difficult to eradicate is found in the 

project area.

• Mixing, storage, and transportation of all herbicides would be controlled. 

• 2,4-D amine (ester formulation) or triclopyr-BEE would not be applied. 

The rehabilitation activities are opportunities to improve soil conditions within the project area. It is 

important to note, these opportunities will be completed if funds are available; they are not requirements of 

the proposed activities in the action alternatives.

Summary of Rehabilitation Treatments (Opportunities)

• Historic skid trails may be present in units that will not be used in this entry. Historic skid 

trails present opportunities to improve degraded soil conditions. These opportunities would be 

selected for subsoiling by the Forest Soil Scientist and timber sale administrator on a case-bycase basis.

• Obliterate and place slash on skid trails one sight distance from open roads to reduce the

potential of illegal motorized use.

• Subsoiling or ripping may be completed on terrace benches in units that are suitable for 

ground-based operations. 

Effectiveness of Mitigations, SWCPs, and BMPs 

Mitigations (Chapter 2, Section 2.3), BMPs, and SWCPs (Appendix A) effectively minimize soil 

disturbance. For example, Han-Sup et al. (2005) found logging during dry months can reduce compaction 

on fine textured soils since soil strength is maximized when soil moistures are less than 10 to 15 percent 

(below field capacity). Harvesting when soils are dry also appeared to limit the machinery impact on the 

wheel track. Above this moisture content, soils are more prone to compaction with the extent of 

compaction being greater in width and depth. 

The State of Montana monitors Forestry Best Management Practices every two years, the last one was 

conducted in the summer of 2006 (State of Montana 2006). A ground-based harvest unit from the 

Bitterroot NF was included in this monitoring effort. Overall, the review found that the Bitterroot NF 

applied the BMPs and SWCPs to harvest operations as required. Effectiveness of the applied BMPs and 

SWCPs was adequate to protect soil and water resources. For a larger perspective, the State Audit in 2004 

(State of Montana 2004) found that across all ownerships, BMPs were properly applied 97 percent of the 

time and overall effectiveness of the implementation was 98 percent. The Lolo National Forest produced a 

BMP Effectiveness Monitoring Report in 2002 (USDA Forest Service 2002). The report found that 

implemented harvest BMPs were effective and recommended additional coarse woody debris be scattered 

across rehabilitated landings, BMP 14.10. 
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-33

Table 3.5-10: Detrimental Soil Disturbance Calculations for All Proposed Treatment Units (Includes all units for both Alternatives 2 &3). 

*Unit Thinning

Treatment Fuels Rx Area (Acres) ExistingDSD (%) 

Logging System

Commercial Units (Acres)

Proposed

Temp Road

(Acres)

Proposed

Swing trails

(Acres)

DSD from

Treatments

(%) 

Existing DSD +

DSD from 

Treatments (%) 

DSD Reduction 

from Rehab 

Treatments (%) 

Total 

DSD 

(%) GB SS TLM

1 NCT & CT Underburn 239.42 19 129.2 26 31 0.72 0.14 10 29 15 13

2 NCT & CT Underburn 196.48 76.1 103.9 9 9 4 3 

3 NCT & CT Underburn 163.20 34 97.8 58.4 7 0.30 9 43 23 20

4 NCT & CT Underburn 142.07 52.2 10 10 4 6 

5 NCT & CT Underburn 34.62 12.4 21.0 9 9 4 3

6 NCT & CT Underburn 35.17 35.2 10 10 10 0 

7 NCT & CT Underburn 24.70 8.0 10 8 8 7

8 NCT & CT Underburn 129.91 42.7 62.3 25 0.83 0.36 10 10 4 4 

9 NCT & CT Underburn 108.70 15.7 61.9 15 0.74 9 9 2 5

10 NCT & CT Underburn 55.31 11.3 39.9 8 8 2 4 

11 NCT & CT Underburn 32.67 30.0 2.7 10 10 9 0

12 NCT & CT Underburn 125.13 7 92.7 13.4 19 1.07 0.21 11 18 12 5 

13 NCT & CT Underburn 84.21 6.9 77.3 8 8 1 5

*14 NCT & CT Pile & burn 19.10 55 3.3 15.7 8 63 12 51

15 NCT & CT Underburn 38.16 2.9 35.2 8 8 1 5

16 NCT & CT Underburn 44.97 5.1 39.9 0.62 10 10 2 4 

18 NCT & CT Underburn 35.72 24.3 8 8 5

19 NCT & CT Underburn 50.63 38.8 12.5 10 10 8 1 

20 NCT & CT Underburn 31.68 3.6 28.1 0.31 0.19 10 10 3 4

*21 NCT & CT Pile & burn 17.46 55 17.5 8 63 10 50

22 NCT & CT Underburn 17.09 17.1 8 8 5

23 NCT & CT Underburn 7.89 7.9 8 8 5 

24 NCT & CT Underburn 19.14 19.0 10 10 10 0

*25 NCT & CT Pile & burn 6.71 55 1.8 4.9 9 64 13 51

26 NCT & CT Underburn 5.86 4.0 1.9 9 9 7 2

*27 NCT Pile & burn 3.56 55 55 10 45

28 NCT & CT Underburn 15.98 16.0 5 5 5

29 NCT & CT Underburn 54.75 8.5 46.3 8 8 2 4

32 Underburn 131.03 0 

33 Underburn 282.33 0 
Affected Environment & Environmental Consequences - Soils

3.5-34 Lower West Fork Project Final EIS

*Unit Thinning

Treatment Fuels Rx Area (Acres)

Existing

DSD (%) 

Logging System

Commercial Units (Acres) 

Proposed

Temp Road

(Acres) 

Proposed

Swing trails

(Acres) 

DSD from

Treatments

(%) 

Existing DSD +

DSD from 

Treatments (%) 

DSD Reduction

from Rehab

Treatments (%) 

Total

DSD

(%) GB SS TLM

34 NCT & CT Underburn 118.86 42.9 10 10 4 6

*35 NCT & CT Pile & burn 35.44 53 4.7 31 0.62 10 63 13 53

40 NCT & CT Underburn 13.29 13.3 8 8 5

41 NCT & CT Underburn 121.31 9.4 104.4 0.30 0.04 8 8 1 5 

42 NCT & CT Underburn 50.99 7.5 38.5 8 8 1 4

60 NCT & CT Underburn 133.45 101.8 28.2 0.76 10 10 8 1 

60A Underburn 30.53 0

61A Underburn 414.47 0 

61 NCT & CT Underburn 417.83 131.0 145.4 8 1.21 0.62 10 10 4 4

62 NCT & CT Underburn 66.28 19.4 46.9 9 9 3 4 

63 Underburn 20.49 0

63B Underburn 32.20 0 

64 Underburn 246.22 0

65 Underburn 39.51 0 

66 Underburn 170.85 0

68 NCT & CT Underburn 161.80 27.3 10 10 2 8 

69 Underburn 26.63 0

70 Pile & burn 199.11 0 

71 Underburn 70.27 0

72 Underburn 4.39 0 

73 Underburn 1.50 1.5 10 10 10 0

74 Underburn 3.71 0 

*75 NCT Pile & burn 20.37 55 55 10 45

80 NCT Pile & burn 23.46 0 

*81 NCT & CT Pile & burn 25.18 57 25.2 8 65 10 52

82 NCT Pile & burn 11.06 0 

83 NCT Pile & burn 13.67 0

84 NCT Pile & burn 2.24 0 

85 NCT Pile & burn 14.62 0

*86 NCT CT Pile & burn 23.38 55 23.4 55 10 50

87 NCT Pile & burn 37.72
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-35

*Unit Thinning

Treatment Fuels Rx Area (Acres)

Existing

DSD (%) 

Logging System

Commercial Units (Acres) 

Proposed

Temp Road

(Acres) 

Proposed

Swing trails

(Acres) 

DSD from

Treatments

(%) 

Existing DSD +

DSD from

Treatments (%) 

DSD Reduction

from Rehab

Treatments (%) 

Total

DSD

(%) GB SS TLM

*88 NCT CT Pile & burn 30.03 55 6.6 23.5 8 63 12 51

*89 NCT CT Pile & burn 60.99 55 61 0.36 9 64 10 50

*90 NCT CT Pile & burn 38.33 55 2.6 35.7 8 63 11 50

91 NCT Pile & burn 28.13 0 

92 NCT Pile & burn 27.44 0

93 NCT Pile & burn 11.93 0 

94 NCT Pile & burn 7.16 0

95 NCT Pile & burn 42.57 0 

96 NCT Pile & burn 22.83 0

97 NCT Pile & burn 4.31 0 

98 NCT Pile & burn 11.00 0

*99 CT Pile & burn 16.34 55 16.3 0.32 2 57 10 52

100 Underburn 30.29 0

101 NCT Pile & burn 8.94 0 

102 NCT Pile & burn 4.46 0

Sum Max Sum Sum Sum Sum Sum Max Max Max Max

5,049 57 1,043.8 1,094.1 355.8 6.56 3.2 11 65 23 53

*Unit = Terrace unit. 

Thinning Treatment – NCT (Non-commercial thin), CT (Commercial thin). 

Fuels RX – Underburn = broadcast burn, Pile & burn = pile & burn. Terraces treatments will leave 10-15 tons of coarse woody debris on terraces benches 

following treatment.

Acres – Total unit acres. 

Existing DSD% - DSD amount currently existing within the unit based on R1 soil monitoring protocol.

Logging System Commercial Units – DSD estimated at 10% for Ground based (GB) yarding and 8% for Skyline (SS) yarding.

Proposed Temp Road Acres – Calculation of temporary road acres based on a 25-foot road base.

Proposed Swing Trail Acres –Skid trails used in skyline operations to move logs from landing to the road system. DSD calculation based on 15-foot trail base.

DSD from treatments – Potential amount of DSD caused from treatments in units.

Existing DSD + DSD from treatments – Cumulative DSD for each unit prior to soil rehabilitation treatments. 

DSD Reduction from Rehab Treatments – Amount DSD reduced by implementing soil rehabilitation treatments. 

Total DSD – Cumulative DSD following all treatments. 
Affected Environment & Environmental Consequences - Soils

3.5-36 Lower West Fork Project Final EIS

C. Cumulative Effects for All Alternatives

Cumulative effects include a discussion of the combined, incremental effects of human activities. For 

activities to be considered cumulative, their effects need to overlap in both space and time with those of the 

proposed actions. For the soil resource, the area of consideration is the harvest unit since effects on soils 

are site specific. Soil erosion and sediment transport, including mass failure, are exceptions. Soil erosion 

is discussed in the Watershed cumulative effects section (Watershed Section 3.6). 

To address cumulative effects this section is organized into three sections.

3. The existing condition, which includes past activities

4. Additional effects from implementation of Alternatives 2 and 3 

5. The effects of on-going and reasonably foreseeable actions

Legacy soil disturbance, from past activities, forms the foundation of the soil conditions on the landscape 

today. These activities include, but are not limited to, timber harvest, grazing, road construction, 

recreation, restoration, and fires. Past activities are listed in Appendix B. Tables 3.5-3 and 3.5-10 illustrate 

the existing level of soil disturbance found in proposed units. 

Existing Conditions and Past Activities

For past, present, or future activities to overlap in time, the effects on soils from the activities must overlap. 

Changes in the physical properties of soil (compaction, displacement, erosion, burning, and puddling) can 

persist for 20-40 years following management activities. Biological soil conditions recover more quickly; 

for example, revegetation generally occurs within 5 years and organic matter begins to rebuild in 10 years, 

but may take more than 50 years to develop humus. Time discussions will look back to at least the 1960s, 

which covers both the physical and biological soil properties. 

Cumulative Effects of Harvest at the Project Scale (Landscape Context) 

Forest management activities have been tracked in the TSMRS database since the 1960’s. Activities that 

had the most impact on soils such as timber harvest and mechanical site preparation were compiled from

the database (Table 3.5-11). 

Table 3.5-11: Cumulative Harvest and Site Preparation Activities in the Project Area

The combined area of activities displayed in Table 3.5-11 total approximately 12,000 acres in the project 

area. Activities have occurred on the same acres in some cases. For example, some shelterwood harvests 

have been followed by clearcut harvests; therefore, the actual area affected by these past activities is less 

than 12,000 acres. 

Harvest activities that have created long term (>50 years) DSD are primarily the result of past groundbased yarding. Yarding practices prior the late 1980’s often did not adhere to soil protection measures such 

as operating on dry soils or designated skid trails. Timber was removed from the forest as economically as 

possible. Soils were compacted and displaced by skidding. Displacement of mineral soil was often 

Past Harvest across the Project Area

Timeframe of 

Past Activity

Type of Harvest or Treatment

Clearcut Salvage Shelterwood Liberation Commercial 

Thin Terrace

Mechanical 

Site 

Preparation

1960s 289 922 362 1,045 22 304 547

1970s 254 616 722 529 --- --- 600

1980s 372 2,412 1,133 130 --- --- 253

1990s 343 390 --- 461 19 --- 61

2000s --- --- --- 210 --- --- ---

Total 1,261 4,340 2,217 2,375 41 304 1,461
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-37

considered desirable because trees regenerated well on these sites.

Based on field surveys, soils in previously disturbed areas are recovering slowly. Previously displaced 

areas have redeveloped organic horizons and are developing productive topsoil horizons in most areas. 

Some areas, such as old landings, burn piles, and major skid trails, exist where minimal organic horizons 

have developed and mineral soils are vulnerable to erosion or weed colonization. Compaction has longer 

lasting effects on soil types with fine textures such as clay loams. Compacted sandy loam to loam soils 

have improved naturally in the surface horizons (approximately 0 to 6 inches). In some cases, subsurface 

compaction persists through 6 to 12 inches of the soil profile. Natural recovery will continue over time 

through freeze/thaw cycles and root penetration, but areas remain that would benefit from subsoiling 

activities to speed the recovery process (Fig. 3.5-1). 

Terracing and mechanical site preparations have had the greatest impacts on soils in the project area. These 

projects involved scraping away vegetation and topsoil to create barren areas for planting. Mechanical site 

preparation typically consisted of piling brush and scraping away organic and topsoil horizons. These 

activities commonly displaced and compacted soils across most of these units. Approximately 1,461 acres 

have been mechanically site prepped across the project area from the 1960’s to 1990’s. 

Terracing and Mechanical Site Preparation across the Project Area

Terraced units in the project area cover approximately 304 acres based on review of project-wide imagery 

(NAIP 2005 & 2009). The terraces were originally constructed in the late 1960’s to promote tree survival 

and growth rates of ponderosa pine plantations. The terracing technique displaced and/or compacted soils 

on the benches. The terrace construction typically disturbed 50 to 80 percent of a selected unit. Most of 

the DSD is located on terrace benches where soils are heavily compacted. The soils have been intensely 

disturbed by displacement, since topsoil horizons were originally cut away and sidecast during 

construction. 

In a study completed on terraced ponderosa pine plantations on the West Fork Ranger District, tree growth 

was measured as tree heights and diameter at breast height. The tree volume was significantly greater in 

the terraced plantations than in the non-terraced control plantations (Zlatnik et al. 1999). This difference in 

tree growth was largely attributed to lower levels of plant competition and improved seedbed conditions 

due to the mechanical planting done on the terraced sites. Other factors improving tree growth on terraces

could be increased snow collection and moisture retention on the terrace benches. The biomass of 

understory vegetation on the terraced units was similar to amounts measured on non-terraced control 

plantations. Soil nutrient and organic matter content in both treatments were similar (Zlatnik et al. 1999). 

Compaction was not measured in the study. Evidence of past soil erosion from the risers to the terrace 

benches can be found but has since stabilized by adequate groundcover. 

Cumulative Effects of Harvest at the Treatment area Scale (Activity Area)

Cumulative activities that have occurred within treatment units are discussed throughout the following 

section. The harvest designs and mitigations proposed for treatments have been developed from field 

review of disturbances from past activities. Discussions for on-going and future projects are found below. 

Field reviews noted that not all past harvest operations cause the same level of soil disturbance and the 

amount and severity of disturbance is highly dependent on soil sensitivity, soil moisture, operator skill, and 

sale administration. 

Proposed commercial thin units in both action alternatives contain land that was contour-terraced in the late 

1960’s. Approximately 273 acres of terraced units are proposed for commercial thinning with an additional 

24 acres proposed for non-commercial thinning in both alternatives. The total 297 acres of terraces in both 

action alternatives will have soil rehabilitation treatments (Fig. 3.5-1, pg 3.5-8). These terraced units 

currently average 55 percent DSD. 

Terraced Units
Affected Environment & Environmental Consequences - Soils

3.5-38 Lower West Fork Project Final EIS

The proposed hand thinning in these units does not pose additional risk to soil productivity since no 

mechanical activities would occur. Thinning will benefit soil condition as slash decomposition provides 

added nutrients and organic matter for soil development. 

Non-commercial Thin Units

Multiple, past management activities have occurred in the proposed treatment units. Most of these units 

have had several entries since 1960. Past vegetation management involved a wide variety of treatments 

including clearcutting, selective harvest, salvage and sanitation, and fuel reduction treatments (Table 3.5-

11). 

Past Harvest and Post Harvest Activity Effects

Harvest techniques prior to the mid-1980s often consisted of handfelling the trees, tractor skidding, 

machine piling slash, and mechanical site preparation (Meurisse 1987). Tractor skidding generally 

occurred in random patterns throughout the unit. Limiting the extent of disturbance, soil moisture 

conditions, and inherent soil sensitivity were not given adequate consideration. Machine piling moved or 

displaced organic matter and topsoil, leaving less fertile subsoil exposed to erosional forces. Displacement, 

compaction, or puddling was commonly observed over 20-50 percent of the unit immediately following 

harvest activities (Meurisse 1987). 

Work by Adams and Froehlich (1984) illustrates that the first few equipment passes cause the greatest 

change in soil bulk density. Soil moisture, rock content, soil texture, type of equipment, and yarding 

practice all play a role in the soil’s susceptibility to static and dynamic forces that can change soil bulk 

density. In 1981, Froehlich showed that designating skid trail locations greatly decreased the areal extent 

of soil disturbance. When skid trails were established at 100 foot spacing, 11 percent of a unit would be 

covered in skid trails (Froehlich 1981). By the mid- to late 1980s, forest practices were changing to 

incorporate these findings. For example, skid trails were designated, season of use considered, and the 

practice of machine piling slash was limited. These and other BMPs, SWCPs, and Forest Plan Standards 

and Guidelines were developed using this research to manage timber harvest yet sustain site and soil 

productivity (Appendix A and State of Montana Department of Forestry BMP program).

Current resource management and harvesting practices give additional emphasis to the season of harvest, 

ensuring that equipment operations are limited to designated areas and that post-harvest activity does not 

reduce soil productivity. Conservation of soil organic matter and CWD are considered in every project. 

Skid trails used in current harvest operations are rehabilitated with waterbars, slash placement, ripping or 

subsoiling, and/or planting shrubs or sowing grass seed to speed natural recovery and keep nutrients and 

soil on site. The intent is to meet and exceed the BMPs and SWCPs outlined in Appendix A. 

The Bitterroot NF has ended the practice of dozer-piling slash, opting for selective grapple-piling using low 

ground pressure equipment or whole tree yarding. This combination of equipment requires repeated trips 

on closely spaced skid trails due to boom-reach limitations of the feller-buncher. The use of low groundpressure FMC torsion-bar suspension skidders substantially decreases the detrimental soil impacts 

(Froehlich, 1978). 

Proposed activities in the Lower West Fork Project overlay small areas of the Rombo Fire. Portions of 

commercial thin units 14, 15, 25, 26, and 88 experienced low and moderate burn severities (Fig. 3.5-1, pg 

3.5-8). Non-commercial thin units 92 and 93 also have areas of low and moderate burn severity. No areas 

of high burn severity were identified in any of the proposed units. The low and moderate severity burn 

areas do not pose a serious risk to soil erosion or soil productivity in these units. Due to the limited burn 

severity in these units, proposed activities will not increase predicted soil disturbance beyond those 

identified in unburned areas. Proposed activities would also not occur until 2010 at the earliest, which 

would give these burn areas at least 21⁄2 years of recovery following the fire.

Rombo Mountain Fire
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-39

Portions of proposed units 64, 71, and 75 were burned by low intensity fire in 2000. The low intensity fire 

did not adversely affect soils. In most cases, soils benefited from the low intensity fire through nutrient

releases into the soil by fine fuels combustion. Cumulative effects of the fires of 2000 will not pose 

adverse effects to soil conditions in combination with the proposed treatments. Areas of high intensity fire 

across the project area are shown in Figure 3.5-2. 

The Fires of 2000

Spotted knapweed and other noxious weeds are present throughout the project area (Noxious Weeds 

Section 3.9). The site-specific effects of these invasions on soil productivity is not known, however, 

research has shown minimal change in soil productivity where the noxious weeds are interspersed with 

native plants (LeJeune and Seastedt 2001; Hawkes et al. 2005). Soil productivity in the form of carbon to 

nitrogen ratios, nitrogen to phosphorus ratios, and soil organism and mycorrhizae communities may be 

altered where noxious weeds form a monoculture (LeJeune and Seastedt 2001; Hawkes et al. 2005). See 

Noxious Weeds Section 3.9 for discussion of cumulative effects related to noxious weed spread. 

Noxious Weeds

Minor cumulative effects to soil productivity would occur under Alternative 2 due to herbicide persistence 

in the soil. The herbicide effects on soil productivity would be very low because less than one percent of 

the project area is proposed for treatment and project design features (Chapter 2) and Best Management 

Practices (Appendix A) would limit exposure. Cumulative effects on soil organisms from herbicide 

applications may also occur; however, these adverse impacts are expected to be short-term. Positive 

cumulative effects would accrue in weed treatment areas where native vegetation communities increase and 

long-term soil stability and quality improve. Overall, long-term soil productivity would be maintained 

under Alternative 2 in compliance with Region 1 standards and guidelines. 

Herbicide Applications

Other foreseeable actions include treatment of weeds by other agencies or by private landowners within the 

portions of the subwatersheds outside the project area. These actions would be evaluated to determine if 

more than the maximum annual allowable treatment area is exceeded for any given subwatershed. Refer to 

Table 3.7-5 (Fisheries Section 3.7-27) for the maximum allowable herbicide application area by HUC 6 

watershed. Picloram application would be the most restricted in the West Fork River and Boulder Creeks 

subwatersheds (worst-case scenario).

Grazing overlaps the proposed treatment units. Impacts of grazing are limited to areas where the animals 

bed, lounge, trail, or access water. These areas are generally small in areal extent. Impacts include 

compaction, removal of groundcover, and displacement. 

Other Activities

Dispersed campsites may be located along the roads and adjacent to or on the edge of harvest units. No 

dispersed camps were noted in the field review. Off-road vehicle use has occurred within the project area, 

primarily on old system road prisms. Field review did note the use of some existing skid trails by OHVs in 

areas with easy access and gentle terrain. In units where existing skid trails are reused, rehabilitation 

activities will include using slash to obscure the trail and discourage illegal OHV use. Slash will also be 

used on landings and recontoured temporary roads to discourage illegal OHV use. 

Other activities described in Appendix B, for example, road construction, reconstruction, maintenance, and 

obliteration, firewood collection, and other past projects have occurred outside unit boundaries and are 

discussed under the watershed cumulative effects analysis.

The CWD requirements for this project are discussed in Direct and Indirect Effects for Alternatives 2 and 

3, and are displayed in Table 3.5-5. The CWD requirements for this project are based on the most current 

science, which differs from the amounts shown in the Forest Plan (SOILS-008). A forest plan amendment 

has been developed to address the CWD issue. The amended CWD requirements for this project will 

Coarse Woody Debris (CWD)
Affected Environment & Environmental Consequences - Soils

3.5-40 Lower West Fork Project Final EIS

encompass less than 0.1 percent of the Bitterroot NF (based on maximum treatment area of 5,056 acres in 

Alternative 2). Since the 1987 Forest Plan, two other forest plan amendments have been made, the Burned 

Area Recovery Project in 2001 and the Middle East Fork Project in 2006. The Burned Area Recovery 

CWD amendment was needed to address soil and site productivity concerns related to salvage following 

Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-43

large fires. Similarly, it was based on current science. Burned Area Recovery treatments comprised 

approximately 0.6 percent of the Bitterroot NF. The Middle East Fork project amendment covered 0.3 

percent of the Bitterroot NF. It was needed to ensure CWD retention in fuel reduction treatments were 

based on current science. Additional amendments have been proposed for the recent Trapper Bunkhouse 

EIS and Haacke Claremont EA. These amendments in combination with Alternative 2 of this project 

(maximum treatment area) cumulatively amount to approximately 1.5 percent of the Bitterroot NF. The 

modifications of the CWD requirements for this project will not have appreciable cumulative effects at the 

site or forest scale.

Cumulatively, by implementing this site-specific standard for CWD and snags, the area is expected to have 

appropriate levels of CWD by fire group over time, fully supporting Forest Plan goals and objectives. 

There is no perceptible cumulative effect of this amendment in conjunction with the thermal cover and elk 

habitat effectiveness Forest Plan amendments. 

The proposed activities in both action alternatives will create additional effects on soils in the activity units. 

The direct and indirect effects are summarized by Alternative in Table 3.5-12. Effects on individual units 

are displayed in Table 3.5-10. These activities add to cumulative soil effects in the project area. 

Rehabilitation treatments will improve soil condition trend in units that exceed the Region 1 standards and 

guidelines. 

Additional Effects from the Implementation of the Proposed Action Alternatives

Table 3.5-12: Summary of Effects on the Soil Resource

1 Includes 65 acres of winter ground-based yarding in Unit 1. 2

This is a conservative estimate of all potential DSD. The soil disturbance estimate is calculated by multiplying the 

number of acres to be treated with the risk of soil disturbance. For example, the risk of soil disturbance on 1,044 acres 

of summer ground-based harvest is 10 percent, which equates to approximately 104 acres.

Discussion 

The estimates of additional soil disturbance (Table 3.5-12) are not absolute but can be used to compare 

differences between alternatives. In essence, the more acres harvested the higher the potential for 

additional soil disturbance. It should be noted that these are conservative estimates of overall DSD as 

defined in FSM 2500 – R-1 Supplement R1 2500-99-1. Precise and definitive calculations of additional 

detrimental disturbance are difficult to attain since detrimental disturbance is a combination of such factors 

as existing ground cover, soil texture, timing of operations, equipment used, skill of the equipment 

operator, amount of wood to be removed, and sale administration. In addition, soil disturbances are 

minimized through the application of mitigation measures, BMPs, and SWCPs (Chapter 2.5 and Appendix 

A).

Alternative

Lower West Fork Proposed Yarding and Hauling

Summer Groundbased

(Acre)1

Skyline & Trackline

(Acre)

New Temporary 

Roads

(Mile)

Potential Soil Disturbance (1) +10% +5 to 8% Skyline + 

Feller/Buncher

25 ft. wide x length of 

road

Total Acres to be Treated

Alt. 1 0 0 0

Alt. 2 1,044 1,450 2.2 

Alt. 3 742 959 1.5 

Potential Acres of Additional Soil Disturbance 2

Alt. 1 – Total = 0 0 0 0

Alt. 2 – Total = 227 104 79 6.6 ac

Alt. 3 – Total = 151 74 71 4.6 ac
Affected Environment & Environmental Consequences - Soils

3.5-44 Lower West Fork Project Final EIS

Alternative 1 would not add to cumulative soil effects unless fires outside of the normal range of variability 

occur. There would be no additional detrimental soil effects since ground-based logging would not occur. 

Noxious weed populations would persist except where currently authorized treatments reduce them. 

Alternative 1

Alternative 2 will produce additional soil disturbance that overlaps in time and space with the existing soil 

conditions. Fire potential, OHV use, and the continuation of active grazing allotments appear to be the 

most likely on-going and reasonably foreseeable actions that would cumulatively affect soil resources. 

Mitigations and rehabilitation will insure Alternative 2 meets the Bitterroot Forest Plan and Region 1 

standards and guidelines. 

Alternative 2

Approximately 227 acres are at risk of increased soil disturbance (Table 3.5-12). The majority of proposed 

treatment units had previous entry; and some units, such as the terraces, exceed Region 1 standards and 

guidelines. Areas of reduced soil productivity include summer skid trails, skyline corridors, temporary 

roads, landings, and burn piles. However, rehabilitation of historic skid trails will improve soil productivity 

in the long-term (more than 10 years). Mitigations (Chapter 2, Section 2.3) and BMPs (Appendix A) 

would limit the severity of any soil damage or its areal extent.

Based on field surveys, Units 1, 3, 12, and all terrace units have disturbance levels that are near or exceed 

Region 1 standards and guidelines. Ground-based equipment would be used in these units in the action 

alternatives, except in the 65-acre area of Unit 1under Alternative 3. Mitigations are prescribed for all 

ground-based units and rehabilitation is proposed on new and historic skid trails to improve soil conditions. 

Terraced units have soil rehabilitation prescribed to improve soil conditions on terrace benches. 

The units at risk for exceeding guidelines will not be further degraded by the proposed action as directed in 

the Region 1 standards and guidelines. The implementation of mitigations and rehabilitation will lead to an 

improving trend in soil productivity in units with DSD. For purposes of this analysis, subsoiling treatments 

are not expected to reduce historic DSD immediately. However, by breaking up subsurface compaction, 

natural processes such as root penetration, soil microbial activity, water infiltration, and freeze-thaw cycles, 

will be accelerated and more capable of recovering the soil to a pre-disturbance condition. The soil 

productivity of the unit will be improved from its current condition. 

Alternative 3 will also produce additional soil disturbance that will overlap in time and space with the 

existing soil conditions. Fire potential, OHV use, and the continuation of active grazing allotments appear 

to be the most likely on-going and reasonably foreseeable actions that would cumulatively affect soil 

resources. Mitigations and rehabilitation will insure Alternative 3 meets Forest Plan and Region 1 

standards and guidelines. 

Alternative 3

Approximately 151 acres are at risk of increased soil disturbance (Table 3.5-12). Areas of reduced soil 

productivity include summer skid trails, skyline corridors, temporary roads, landings, and burn piles. 

However, rehabilitation of landings and burn piles will improve soil productivity in the long-term. 

Rehabilitation of terraced units and historic skid trails will create a net improvement in soil quality.

There are no on-going or reasonably foreseeable timber harvest units overlaying any of the proposed units 

in the action alternatives. Grazing will continue to have similar cumulative effects as those described 

above under Past Actions. New dispersed recreation and hunting camps may be located along the roads 

and adjacent to or on the edge of units. OHV use will continue in the area consistent with forest 

designations of off-road vehicle use. Fires are always a possibility and may overlap the proposed units. 

Other activities described in Appendix B, for example road construction, reconstruction, maintenance, and 

obliterations, firewood gathering, and other past projects will continue but are typically outside of unit 

boundaries. 

The Effects of On-going and Reasonably Foreseeable Actions
Affected Environment & Environmental Consequences - Soils

Lower West Fork Project Final EIS 3.5-45

3.5.5 REGULATORY FRAMEWORK AND CONSISTENCY

A. Region 1 Soil Quality Standards and Region 1 Supplement 2500-99-1 

All proposed activities are designed to meet the Region 1 standards and guidelines and Supplement 

direction. These guidelines require that soil properties and site characteristics be managed in a manner 

consistent with the maintenance of long-term soil productivity, soil hydrologic function, and ecosystem 

health. Upon completion of activities, at least 85 percent of an activity area must have soils in satisfactory 

condition. Activities within harvest areas are designed to detrimentally disturb less than 15 percent of the 

activity area. There are proposed units that currently exceed the 15 percent guideline. Rehabilitation 

activities will take place on used skid trails in all ground-based units to recover both old and newly created 

compaction. Terrace benches will be rehabilitated following thinning activities. The rehabilitation 

activities in these units will result in a net improvement in soil productivity.

B. Forest Plan Management Direction 

Forest wide standards for soil resources in the Forest Plan are found in Chapter II, pages 17-33, and 

Chapter III under the individual management areas, page II-46. The Bitterroot Forest Plan does not have 

numeric Soil Quality Standards; however, the plan addresses soils in the following standards and 

guidelines. 

Ø Page III-6(3) Provide soils technical support for management activities on sensitive soils. 

• How addressed: The Forest Soil Scientist participated on the IDT and will participate in the 

implementation as needed.

Ø Page II-25(7) Plan and conduct land management activities so that reductions of soil productivity 

potentially caused by detrimental compaction, displacement, puddling, and severe burning are 

minimized. 

• How addressed: The Forest Soil Scientist field reviewed all of the proposed units in all action 

alternatives for existing site conditions.

• Utilizing this data, the Forest Soil Scientist was able to plan, design, and prepare 

implementation mitigations and rehabilitation treatments to protect soil productivity. The 

mitigations are found in Chapter 2 of the document. The ID Team reviewed the mitigations in 

Chapter 2 so they are integrated between the resource areas. 

Ø Page II-25(8) Plan and conduct land management activities so that soil loss, accelerated surface 

erosion, and mass wasting caused by these activities will not cause an unacceptable reduction in 

soil productivity and water quality. 

• How addressed: See above discussion under Page II-25(7). 

Ø Page II-25(9) Design or modify all management practices as necessary to protect land productivity 

and maintain land stability. 

• How addressed: See above discussion under Page II-25(7). 

Ø Page II-25(6) Soil and Water Conservation Practices will be a part of project design and 

implementation to ensure soil and water resource protection (FSH 2509.22). 

• How addressed: SWCPs (Appendix A) are linked to the timber sale contract provisions to 

insure implementation. Timber Sale Administrators monitor the implementation of BMPs and 

SWCPs during harvest and post-harvest activities.

Ø Page III-6(4) identifies the level of organic matter and coarse woody material following harvest.

• How addressed: Target levels for coarse woody material are found in Table 3.5-5. The levels 
Affected Environment & Environmental Consequences - Soils

3.5-46 Lower West Fork Project Final EIS

of coarse woody material have been modified for the action alternatives based on site-specific 

information (Proposed Forest Plan Amendment, Chapter 2) and the purpose and need of the 

project (Chapter 1). The amendment allows a quantitative measurement of the amount of 

coarse woody material to be left by fire group. The amended CWD requirements for this 

project will encompass less than 0.1 percent of the Bitterroot NF (based on maximum 

treatment area of 2,493 acres in Alternative 2). Since the establishment of the Forest Plan in 

1987, two other allowances have been made and two are currently being proposed. These 

amendments in combination with this project cumulatively amount to approximately 1.5 

percent of the forest. The modifications of the CWD requirements for this project will not 

have appreciable cumulative effects at the site or forest scale.

C. National Forest Management Act 

The National Forest Management Act requires the Forest Service to insure that timber will be harvested 

only where soil will not be irreversibly damaged (16 USC Section 1604 (g)(3)(E)(i)) and even-aged 

regeneration harvest be carried out in a manner consistent with the protection of soil (16 USC Section 1604 

(g)(3)(F)(v)). The intent is that by maintaining productivity of the parts (i.e. the treatment areas), the 

productivity of the land will be maintained on the larger scale. 

Proposed activities in Alternatives 2 and 3 will not result in irreversible damage to the soil resource. 

Proposed activities that will have the greatest affect on soil are ground-based yarding. Skid trails will be 

designated and historic skid trails will be used to the greatest extent feasible to limit new disturbance. 

Rehabilitation activities (subsoiling) are proposed to alleviate the impacts of compaction on reused and new 

skid trails. 

Limited data has been released from the Long-term Site Productivity Project (LTSP) (Powers et al. 2005; 

Powers et al. 2004). Data released from the first 10 years (Sierra Nevada and Southern Coastal Plain sites) 

suggests that site productivity has not been impaired despite substantive soil compaction and a massive 

removal of surface organic matter on the test plots (Powers et al 2004). The authors also suggest that there 

is no evidence that the 10-year productivity was universally impacted by soil compaction. Possible 

explanations include that the increase in bulk density was not severe enough, bulk density changes are 

strongly tied to initial soil bulk density, or that high bulk density in coarse soil increases the water holding 

capacity on droughty soils. The authors caution against using this information for other sites and climate 

and the data suggests only 10 years of study and that future data may alter the above conclusions.

Powers (1990) defines the processes that lead to declines in soil productivity. He concludes that limiting 

the loss of biomass, organic matter, soil porosity, and topsoil should preserve soil productivity. The use of 

BMPs, SWCPs, and mitigation measures in the Lower West Fork Project would protect organic matter, soil 

porosity, and topsoil. Localized and limited losses will occur on landings, skid trails, temporary roads, or 

where fire sterilizes the soil. However, over most of a unit and the landscape, soil productivity and the 

processes that lead to soil productivity will be preserved.

D. Monitoring 

Soil monitoring of Lower West Fork project timber sale activities will be part of the annual soil monitoring 

program on the Bitterroot NF. To accomplish this task, soils will be evaluated against definitions and 

guidelines provided in the Forest Plan, as well as Forest Service Manual 2550 (Amendment No 2500-90-2 

and Region 1 Supplement 2500-99-1), and Handbook 2509.18 (WO Amendment 2509.18-91-1 and Region 

1 Supplement 2509.18-2005-1). Treatment units will be randomly selected and monitored for 

implementation and effectiveness of mitigations, BMPs, and SWCPs. Detrimental soil conditions will also 

be monitored to determine if post harvest activities are within Region 1 standards and guidelines. 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-1 

3.6 WATERSHED

3.6.1 INTRODUCTION

The watershed analysis focuses on the current watershed condition and the effects of the implementation of 

the alternatives on the water resource. It includes evaluation of sediment sources, water yields, and past 

activities that have contributed to existing conditions. 

3.6.2 REGULATORY FRAMEWORK

A. Forest Plan Direction 

The Bitterroot National Forest Land Management Plan (Forest Plan) describes Forest-wide standards that 

apply to the water resource. The Forest Plan directs managers to maintain soil productivity, water quality 

and water quantity (USDA Forest Service 1987, pg. II-3). Forest-wide Management Objectives state that 

riparian areas will be managed to prevent adverse effects on channel stability and fish habitat (USDA 

Forest Service 1987, pg. II-6). The Forest Plan was amended in 1995 to include INFISH (USDA Forest 

Service 1995) management standards. The management standards prescribe mandatory buffers between 

activity units and streams, wetlands, and landslide-prone areas. The Fisheries section 3.7 describes INFISH 

in more detail. 

The Forest Plan also directs management to “actively reduce sediment from existing roads” (USDA Forest 

Service 1987, pg. II-25). Sediment reduction practices include graveling roads and ditches; stabilizing cut 

and fill slopes with vegetation, mulch, or netting; filtering sediment using straw bales or slash filter 

windrows in sediment contributing areas; and directing road drainage into vegetated filters away from 

streams. Selected soil and water conservation practices (also known as Best Management Practices 

(BMPs)) are part of the project design and implementation to protect soil and water resources (USDA 

Forest Service 1987, pg. II-25). 

B. Montana Streamside Management Zone Act 

The Montana Streamside Management Zone Act (SMZ) establishes management zones along streams and 

wetlands. The SMZ buffers the stream from forest activities and prevents upland sediment from entering 

streams. This act prohibits several forest practices within the SMZ. Activities on the Bitterroot National 

Forest (Bitterroot NF) must comply with the SMZ law. The State required SMZ is narrower than the 

INFISH required buffers. The Bitterroot NF complies with the SMZ Act by adhering to the more 

restrictive INFISH requirements. 

C. Montana State Water Quality Standards 

The Montana Department of Environmental Quality classifies all surface water as B-1 (ARM 16.20.604). 

The beneficial uses associated with B-1 surface waters are drinking; culinary and food processing after 

conventional treatment, bathing, swimming and recreation; growth and propagation of salmonid fishes and 

other aquatic life, waterfowl, furbearers, and other wildlife; and agricultural and industrial water supply 

(ARM 17.30.607 & 623). 

Circular DEQ-7 specifies the Montana Numeric Water Quality Standards (MDEQ 2008). Montana Water 

Quality Standards prohibit chemical concentrations that are toxic or harmful to aquatic life in surface 

waters, including herbicides used to control invasive plants. 

D. Clean Water Act 

Section 303(d) of the Clean Water Act (CWA) directs states to list water quality impaired streams and 

develop total maximum daily loads (TMDL) to control non-point source pollution. The Montana 

Department of Environmental Quality (DEQ) evaluated the West Fork Bitterroot River (West Fork River) 

in 2005 (Table 3.6-1) and assigned a road sediment reduction target of 57 percent from existing levels
Affected Environment and Environmental Consequences - Watershed

3.6-2 Lower West Fork Project Final EIS 

The West Fork Bitterroot River is 

listed as an impaired stream.

The Lower West Fork project, 

must demonstrate that it will not 

further degrade the West Fork of 

the Bitterroot River.

(DEQ 2005). This target represents the estimated sediment load that would remain once all contributing 

road treads and cut and fill slopes are reduced to a maximum of 200 feet. Any planned activities will need 

to demonstrate that further degradation of impaired waters would not occur and would contribute towards 

the reduction of sediment sources identified in the TMDL analysis (DEQ 2005). Consultation with the 

DEQ and Environmental Protection Agency (EPA) has occurred during analysis of this proposal. 

Table 3.6-1: Impaired Water Body and Probable Cause(s) for Impairment in the Lower West Fork 

Project Area

Best Management Practices (ARM 16.20.603) are the foundation of 

water quality standards for the State of Montana. When properly 

applied, BMPs limit non-point source pollution. Non-point source 

pollution comes from diffuse sources (Ethridge 2004), which cannot 

be traced to a specific source or activity. Sediment is a non-point 

source pollutant typically associated with timber harvest and road 

construction. These two activities expose soil, which can then be 

transported to waterways during storms. Contract administrators and 

resource specialists routinely monitor BMP implementation. 

Administrative Rules of Montana (ARM) 16.20.603 

This regulation details water quality standards for the State of Montana. The Forest Service has primary 

responsibility to maintain these standards on National Forests in Montana. 

ARM 17.30 Sub-chapter 6 

Montana Department of Natural Resources and Conservation audited BMP application and effectiveness on 

federal lands (Rogers 2006). They reported that BMPs were properly applied 93% of the time and were 

95% effective in preventing water quality degradation. The report showed that streamside management 

zones were applied properly 100% of the time, and were 100% effective. BMP monitoring after Burned 

Area Recovery project implementation shows that BMPs within harvest units were properly applied and 

effective (USDA Forest Service 2006). Bitterroot NF hydrologists monitored BMP application on three 

timber sales in 2007 and found they were applied and effectively protecting water quality (PF-WAT-12). 

The BMPs incorporated into the timber sale contract clauses were checked several times each week by 

timber sale administrators. The problem areas were limited in size, and easily corrected with additional 

planting or seeding. None of the problem areas transported sediment into streams or wetlands. During 

spring break-up, log hauling on roads adjacent to streams has the highest potential of transporting sediment 

(USDA Forest Service 2006, Forest Plan Monitoring Report Item 22). 

This law mandates the identification and control of nonpoint-source pollution caused by silvicultural 

activities.

Federal Water Pollution Control Act (Public Law 92-500) Section 208

3.6.3 ANALYSIS AREA AND ANALYSIS METHODS

Piquett Creek hydrologic unit (Hydrologic Unit Code 170102050303 or HUC 0303), Lower West Fork 

(HUC 0305), and Boulder Creek (HUC 0302) make up the direct and indirect effects analysis area (Figure 

3.6-1). The Lower West Fork HUC includes the main stem of the West Fork River from the confluence of 

Waterbody # Name USGS 6th

level HUC

Est. 

size 

(mi.)

Beneficial 

Use, Partial 

Support

Probable Cause Probable Source

MT76H003_010

West 

Fork 

Bitterroot 

River

1702050305 39.4

Aquatic life 

support, cold 

water fishery 

(trout)

Physical substrate 

habitat alterations, 

sediment or 

siltation

Highways, roads, bridges, 

infrastructure (new 

construction); streambank 

modification or destabilization
Lower West Fork Project Final EIS 3.6-3 

Figure 3.6-1: Analysis Area and Watershed Boundaries in the Lower West Fork Project
Affected Environment and Environmental Consequences - Watershed

3.6-4 Lower West Fork Project Final EIS 

the Nez Perce Fork, to Pierce Creek, Lavene Creek, Christisen Creek, Violet Creek, Pine Creek, and other 

small streams that flow into the West Fork River. 

These areas were chosen because they contribute water and sediment to the West Fork River that is within 

and downstream of the project area. The cumulative effects analysis area includes watersheds that are 

outside of the project area but contribute to West Fork River conditions: Nez Perce Fork (HUCs 0203, 

0202, 0201, 0204) and the West Fork to Painted Rocks Dam (HUC 0301). Painted Rocks Dam traps 

sediment from the upper reaches of the West Fork River so the area above the dam was not include in the 

cumulative effects analysis area. The dam also alters the flow regimes of the West Fork River by storing 

water from peak flows and releasing water during the summer low flow period. This analysis focuses on:

Ø sediment production 

Ø water yield

Ø stream channel condition 

Ø water quality 

A. Stream Sedimentation 

We evaluate stream sedimentation effects by assessing sediment delivery from roads, and vegetation and 

fire management. During project implementation, activities such as yarding timber, hauling logs, 

constructing log landings and temporary roads, and prescribed fire commonly produce sediment. The 

reduction of sediment delivery to streams, as mitigated by application of BMPs, is included in the analysis.

The Forest Service used the same methodology as the DEQ used in its report, 

Roads

Water Quality Restoration 

Plan and Total Maximum Daily Loads for the Bitterroot Headwaters Planning Area (Restoration Plan) 

Appendix E (DEQ 2005), to estimate road-related sediment in the project area. In the Restoration Plan, 

crossings within listed streams were evaluated by measuring and calculating sediment area and sediment 

contributions to streams. The results were extrapolated to non-listed tributaries and to stream crossings not 

visited in the inventory. In the West Fork River system, the Restoration Plan estimates sediment 

contributions at 1.7 tons for each crossing. The strengths and weaknesses of this methodology are 

described in the project file (PF-WAT-31). This analysis provides estimates

This methodology is appropriate to use in the analysis because it has been calibrated using field 

measurements from the project area, and is comparable to the Restoration Plan analysis. The road 

associated sediment estimates in the Lower West Fork alternatives can be displayed relative to Restoration 

Plan outputs and recommended reductions. 

of sediment, not absolute 

quantities, to compare the relative effects between alternatives.

Increased traffic, especially logging traffic, increases the potential for sediment runoff and delivery to 

streams if the road is located within sediment contributing distance (300 feet). Two roads encroach within 

300 feet of streams in the project area – NFSR 363 on Pierce Creek and NFSR 5630 on Lavene Creek. 

We estimate sediment production and delivery to streams from the proposed vegetation management and 

prescribed fire treatments using the Disturbed Water Erosion Predictive Project model (Disturbed WEPP) 

and information from Bitterroot NF field monitoring. The Disturbed WEPP model estimates the amount of 

sediment produced by ground disturbance and loss of soil cover associated with prescribed fire and harvest 

activities such as log yarding, log landings, and fuel reduction (Elliot et al. 2000). Fuel reduction units 

typically include mechanical treatment of fuels followed by prescribed fire. Some fuel reduction units are 

scheduled for prescribed fire treatment only. We did not model pre-commercial thinning units that do not 

require heavy equipment or prescribed fire because soil disturbance is not associated with this treatment. 

The Disturbed WEPP model uses terrain, ground cover and climate variables to estimate erosion rates and 

the probability of eroded soil reaching a stream channel (delivered sediment). 

Vegetation Management
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-5 

Forest monitoring has 

shown that good sale 

administration and 

specialist monitoring has 

reduced the risk of 

sediment inputs to 

streams from log hauling. 

Similar monitoring is 

planned for any action 

alternative.

The Disturbed WEPP model is one of the best available tools for assessing soil erosion and sediment 

production. The project file contains more detailed information about this model, including its strengths 

and weaknesses (PF-WAT-31). 

The estimated sediment contributions from vegetation management and burning activities are reported as if 

all activities occur in one year. In reality, the proposed activities would occur over a period of several years 

and the annual contributions to streams would be a portion of the estimated totals displayed. 

Generally, forests have very low erosion rates unless soils are disturbed (Elliot 

et al. 2000). Estimates from the Disturbed WEPP model indicate that 

sediment delivery to streams would be undetectable from undisturbed forest 

stands (PF-WAT-5 and WAT-19). Sediment produced from timber harvest 

older than five years and fires older than three years was not included in this 

analysis because erosion and sedimentation are approaching pre-project 

levels. Research and monitoring of timber harvest and fires show that ground 

disturbance resulting from these events stabilizes within two to six years, and 

sediment is not transported off site (USDA Forest Service 2006, Item 22; 

Luce and Black 2001, Elliot et al. 2000, 2003 Forest Plan Monitoring Report 

Item 22, USDA Forest Service 1991). Professional judgment based on site 

visits and monitoring of similar projects (USDA Forest Service 2003) is used 

to estimate the effects of increased sediment on water quality and stream 

channel conditions. 

B. Water Yield

Modeling Equivalent Clearcut Area (ECA), a simplified version of the WRENSS model (USDA 1974), 

was used as a “coarse screen” to determine the probability of a harvest-related water yield increase (PFWAT-31). When the ECA in a 6th-level watershed is below 20-25%, we would not expect water yield to 

increase (Stednick 1995, Troendle et al. in press) and therefore, no changes in channel stability. If the ECA 

in a 6th-level watershed is projected to go above 20%, we surveyed stream characteristics to determine 

stream channel stability. If the percentage of forest cover affected was less than 20%, we assumed a low 

probability of a detectable water yield increase and did not analyze it further.

Precipitation has the most influence on runoff and water yield, and most changes in stream channels are the 

result of climate fluctuations rather than forestry applications (PF-WAT-9, WAT-10, MacDonald and 

Hoffman 1995). The Lower West Fork is a large analysis area and annual precipitation ranges between 20 

and 85 inches, with the greatest precipitation occurring in the headwaters or higher elevations of Boulder 

and Baker Creeks. Annual precipitation in most of the analysis area is between 20 and 45 inches, with the 

managed areas being in the 20-35 inch zone. Research shows that stream channel changes do not occur 

following timber harvest alone, but occurs following timber harvest in combination with other factors 

(Stednick 1995, Troendle 1987, Troendle et al. 2001). Sedimentation and increased stream flows caused 

channel changes following timber harvest (Rice 1981). For this reason, in watersheds where increased 

flows are of concern, mitigation and project design are used to reduce sediment inputs. The ECA model 

also addresses cumulative effects as it considers prior treatments and their changing effects over time. 

More detailed information about the model is in the project file (PF-WAT-25). The ECA does not identify 

actual channel conditions. We assessed channel conditions using the methods detailed below. 

C. Channel Conditions

Stream surveys (PF-WAT-2) included channel geometry and stability measurements, Rosgen (1996) stream 

type classification, and substrate composition and productivity. We surveyed several streams using an 

abbreviated survey that incorporated a channel stability rating along with a stream-walk to determine 

stream conditions along several hundred feet of stream. Watershed and fisheries personnel conducted 41 

visits to streams within the project area between 1992 and 2005. A listing of surveyed streams and the data 
Affected Environment and Environmental Consequences - Watershed

3.6-6 Lower West Fork Project Final EIS 

collected are in the project file (PF-WAT-2). Stream channels evolve and adapt in response to upstream 

conditions and events, both man caused and natural (MacDonald et al. 1991). Therefore, streams are an 

indicator of upstream watershed conditions and the effects of past activities. Surveys assess actual stream 

channel conditions, and are very good indicators of watershed health. We compared the stream survey data 

to reference stream data to evaluate stream health. 

D. Herbicides

We analyze herbicide use as a contingency for controlling the spread of noxious weeds, under Alternative 

2. This analysis tiers to the Selway-Bitterroot Wilderness Weeds Draft Environmental Impact Statement 

(SBW Weeds DEIS) (USDA Forest Service 2008d). This analysis compares the effects of various 

herbicides and their toxicities on aquatic organisms, including fish. Much of the information presented in 

the Lower West Fork analysis is a summary of information contained in the SBW Weeds DEIS. 

Herbicides proposed for use have relatively low aquatic toxicity (Table 3.7-5) Their specific toxicity 

characteristics are discussed in Appendix I of the SBW Weeds DEIS (USDA 2008d), and the SBW Weeds 

Fisheries Biological Assessment (BA) (USDA 2008b, pg. 26-48). Table 13 in the BA (pg. 28) summarizes 

the aquatic toxicology of the herbicides that could be used in Alternative 2. Of the herbicides that are most 

commonly used on the Bitterroot NF and likely to be used in Alternative 2, picloram is the most toxic to 

fish, while 2,4-D, aminopyralid, and clopyralid are several orders of magnitude less toxic (USDA 2008: pg 

28; USDA 2009: pg 3.3-24). 

The maximum treatment area (acres) proposed for each herbicide in a 6th-level watershed is the indicator of 

aquatic risk of adverse effects. Three methods are referenced in comparing toxicity to fish and other 

aquatic organisms: Lethal Concentration (LC50), No Observed Effect Level (NOEL), or No Observed 

Effect Concentration (NOEC). Although the LC50 is frequently used as a toxicity standard, 50 percent fish 

mortality is generally not acceptable. For this reason, NOEL or NOEC are better parameters for evaluating 

effects (Refer to Fisheries Section of page 3.7-21 for more detailed information on toxicity). Toxicity is a 

known value using NOEL or NOEC, and is related to the maximum area of treatment for each herbicide. 

The herbicide effects on fish can be quantified using the 96-hour LC50. The 96-hour LC50 refers to the 

concentration that is lethal to 50 percent of the fish exposed at that level for 96 hours. The lower the LC50, 

the more toxic the compound. The 96-hour LC50 for the proposed herbicides (plus the parent compound of 

2,4-D amine) is provided in Table 3.3-12 in the SBW Weeds DEIS. For example, NOEL for picloram on 

cutthroat trout is 0.29 milligrams per liter (1mg/l = 1 part per million (ppm)). Because there are few longterm test results that identify safe concentrations (NOEL), the EPA recommends the 96-hour LC50 divided 

by 20 as the standard to protect endangered aquatic species. These concentrations are the benchmarks used 

to evaluate the level of risk of adverse effects).

The NOEL or NOEC was used in place of the LC50 when it was available from studies. These levels 

represent a conservative approach to evaluating the active ingredients of the proposed herbicides within 

each watershed. NOEL/NOEC is the highest concentration of toxicant to which organisms are exposed in a 

full or partial life-cycle test that causes no observable effect on survival, growth, or reproduction. This 

would mean there is no significant difference between the test solution and the control, as determined by 

hypothesis testing. 

3.6.4 AFFECTED ENVIRONMENT

A. Existing Sediment Sources 

Fire suppression has reduced the incidence of fire in the analysis area and has reduced the episodic pulses 

of sediment that occurred following fire. Historically, sediment pulses occurred following fire and during 

high flow erosion events. As fire returns to the landscape, sediment pulses associated with the fires would 

Fire
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-7 

be expected. Fire suppression has also altered vegetation patterns on the landscape increasing stand density 

and tree encroachment into grasslands. These conditions have decreased soil moisture levels and possibly 

decreased water yields in the analysis area. 

The 2007 Rombo Fire burned 7,300 acres at high or moderate intensity in the Piquett watershed. Most of 

the high intensity fire occurred in Britts Creek, a largely unmanaged watershed north of Castle Creek. In 

upper East Piquett watershed and upper Piquett watershed, fire intensity was mixed. Erosion estimates in

the Burned Area Emergency Recovery Report (PF-WAT-26) were made using Disturbed WEPP with the

ERMit interface. The ERMit interface is a WEPP technology that estimates erosion on burned lands (Elliot 

et al. 2006). Modeling of worst-case scenarios estimated erosion at 15.4 tons/acre and sediment 

contributions at 8.6 tons/acre. The Rombo fire will likely be the largest sediment source in the Piquett 

watershed for the next several years, especially if storms cause debris flows. 

On July 25, 2009, a thunderstorm occurred in the Piquett and Warm Springs drainages that caused dark, ash 

colored turbidity in Piquett Creek and the West Fork River below Piquett Creek in the morning of July 26 

through the morning of July 27. Since there are no rain gages in this portion of the Forest, it is not possible 

to quantify the storm event but it appears to have been a high intensity, high precipitation storm. Fire 

aircraft flew the area after the event but were unable to locate any erosion sites. The erosion event must 

have occurred in the unmanaged, roadless portion of the Piquett and Warm Springs drainages because 

review of the roaded portions found no evidence of high flows, large amounts of sediment deposition, or 

debris torrents at any of the crossings on the main road. As the turbidity cleared, deposition of silt and ash 

on the substrate in both streams was observed, making the stream bottom dark colored. Water releases 

from Painted Rocks Dam following the erosion event have transported the new deposition in the higher 

velocity sections of the river (riffles) to low velocity areas downstream. 

It is likely that channel changes such as bank and substrate erosion, channel scour, and sediment deposition 

have occurred in the individual tributary (or tributaries) to Piquett Creek where the storm and erosion event 

took place. Over the next several to ten years this channel will stabilize and revegetate as seen in small 

tributaries to Laird Creek that had large debris flow events following the fires in2000. The materials 

removed from the individual tributaries and deposited in Piquett Creek and the West Fork River will be 

transported downstream during future high flow events, such as next year’s spring runoff. This type of 

event occurs after wildfire and though there are periods of decreased water quality (turbidity increase, 

sediment transport, and deposition) they are usually short term, and a ‘natural’ occurrence. 

The Lake of the Rocks Fire, a wildland use fire, burned an estimated 950 acres in the Boulder Creek

drainage in 2006. Boulder Creek is a largely unmanaged watershed and the fire was classified as a mostly 

“stand replacing” fire. A stand replacing fire is defined as a fire that kills all or most of the overstory trees 

in a forest and initiates forest succession or regrowth (Glossary of wildland fire terminology, National 

Wildfire Coordinating Group 2005). No evidence of debris flows or other fire related episodic large 

erosion events has occurred as of September 2009. If this type of event were to occur, it would occur 

during high precipitation events in 2008 before vegetation is re-established on the burned areas. 

Small portions of the Piquett watershed burned in 2000. Sediment contributions to streams should be 

approaching pre-fire levels since it has been eight growing seasons since the fires in 2000. Field review of 

burned areas within the analysis area indicates that vegetation has recovered and fire-caused sediment is not 

measurable on hillslopes. Studies show that by the fourth year, fire associated erosion is negligible (Elliot 

and Robichaud 2001). 

Prescribed fire has occurred in various locations on the west side of the West Fork River in order to reduce 

fuel loading near private land and to restore lower elevation ponderosa pine communities. The School 

Point project is an ongoing effort to reduce fuels and extends from School Point southeast to Halford 

Creek, a tributary to Nez Perce Fork.
Affected Environment and Environmental Consequences - Watershed

3.6-8 Lower West Fork Project Final EIS 

All roads in the analysis area were inventoried in 2005 and 2006 (PF-WAT-27). These inventories 

identified several locations depositing sediment into streams. Roads crossing streams are potential 

sediment contribution points (King and Gonsior 1981; Logan and Clinch 1991, Burroughs 1990). Many 

roads cross streams in this analysis area. Some of the crossings have been treated to reduce sediment 

inputs, others have been identified for treatment and are included in the alternatives. Examples of sediment 

sources identified during the inventories are washed out or plugged culverts, erosion of unstable fill, and 

erosion of over steepened fill at previous culvert removal sites. These types of sediment sources have been 

proposed for treatment through maintenance, road storage, or road decommissioning. The inventories also 

identified many areas that were not erosive and not contributing sediment to streams. This information was 

used to refine the analysis models and more accurately portray conditions in the analysis area.

Roads

Recent road improvements in the analysis area have reduced sediment sources including those identified in 

the Frazier Interface EA (Frazier project). The segment of NFSR 363 that closely parallels Pierce Creek, 

was graveled and reshaped in 2004 to reduce deposition of sediment into Pierce Creek. NFSR 5629 

parallels Frazier Draw for 0.4 mile but is mostly higher on the hill slope and there are few sediment input 

sites. One section of road identified as a sediment input site was re-shaped and graveled in 2004. A culvert 

on NFSR 74348, where water was flowing over the road and eroding the road surface, was also removed 

and the road prism reshaped and seeded. 

The Nez Perce Watershed Restoration and Travel Management Decision Memo (1997) stored, gated, or 

decommissioned roads in the Nez Perce Fork watershed and on the west side of the West Fork River from 

the Nez Perce Fork to Trapper Creek. Improvements were completed on 27 of the 28 roads (24 miles) in 

the Lower West Fork project area in 1997 and 1998 (PF-WAT-14). Work included seeding eroding areas, 

changing the season of use, and decompaction of road surfaces. The 2005 and 2006 road inventories found 

the projects were implemented as planned and achieving their purpose. 

The east side of the West Fork River has had few recent watershed improvements. In 2006, NFSR 13431 

was placed in storage as part of the Burned Area Recovery Project (2001) and an illegal OHV trail in East 

Piquett was blocked with slash and seeded so it would revegetate and prevent the spread of noxious weeds. 

NFSR 49 is located in the valley bottom of Piquett Creek. However, the valley width and flat gradient 

prevent road sediment from reaching the Creek. The only potential sediment input points are at the stream 

crossings because the road is built against the toe of the slope. The low gradient at the crossings keeps 

runoff from building enough momentum and energy to carry sediment into the stream. Sediment 

contributions at the stream crossings are very small.

Table 3.6-2 displays the number of stream crossings in subwatersheds. The average annual sediment 

contribution of 1.7 tons /year is based on 218 crossings analyzed in the Restoration Plan (DEQ 2005). The 

number of crossings in the Lower West Fork analysis area was determined using GIS overlays of the road 

and stream systems (PF-WAT-16). The 2005-2006 road inventories found several culverts were mapped 

that did not exist and some had not been mapped. They also found that some of the crossings were not 

contributing sediment to streams or drainages. These findings were field verified in 2007 and the 

information used to portray stream sedimentation points on roads and estimate sediment contributions. 

Subdivision and private land development have occurred along the West Fork River and the lower 

elevations of some tributaries. This development may include construction of access roads and timber 

harvest or fuel reduction and may have caused vegetation changes along streams. However, wildfire and 

roads are the largest contributors of chronic sediment in streams. 

B. Existing Stream Conditions 

Riparian areas and wetlands occur throughout the analysis area. Well-vegetated riparian areas filter and 

clean water flowing overland; they provide habitat for wildlife, and shade to help maintain cool stream 

temperatures. Typically, linear wetlands are found along the stream and riparian areas that absorb water
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-9 

Table 3.6-2: Sediment Contributions from the Road System in the Lower West Fork Project 

during high flows and release cool, clean water during summer. At stream survey sites, riparian vegetation 

was growing vigorously along stream banks. In areas of previous harvest, where the conifer overstory was 

removed, a high-shrub component is present and banks are well vegetated with brushy shrubs and grasses. 

Roads that parallel the stream channel constrain riparian functions in areas along Pierce Creek, on a few 

sections of Piquett Creek, and to some degree Frazier Draw. The roads reduce stream shade and floodplain 

width, which moderates stream temperature, and confines channel migration and sinuosity. In the uplands, 

culverts on roads interrupt the linear riparian feature and serve as a conduit for sediment to enter streams. 

There are several mapped stream types within the analysis area (PF-WAT-2). Using Rosgen’s stream 

classification system (1996), stream type A is the most common stream type in the project area but stream

type B is more common in the larger stream systems at lower elevations. Stream type “A” channels are

fairly straight, high gradient streams (greater than 4% water surface slopes) with narrow floodplains. 

Baker, Pierce, and most of East Piquett creeks are examples of stream type “A” in the analysis area. Type 

“A” streams have step/pool morphologies and are capable of transporting sediment throughout the year. 

Stream type “B” has a more gentle gradient than stream type A (typically between two and four percent), a 

more developed floodplain, and is moderately sinuous. Piquett Creek below NFSR 5720 crossing and most 

of the West Fork River are examples of stream type “B” in the analysis area. Type “B” streams typically 

carry sediment throughout periods of high flow and deposit it during lower flows. There are a few reaches 

of stream type “C” on the West Fork River near the West Fork Lodge. Stream type “C” channels are low 

gradient, meandering, pool-riffle streams with wide, well developed floodplains. The discussion below, 

which is based on surveys, describes existing stream channel conditions. Tables 3.6-3 – 3.6-5 display the 

existing subwatershed conditions in the specific HUC.

Table 3.6-3: Existing Condition of HUC 0302, Boulder Creek

Boulder Creek, HUC 0302

Stream Name Total Number of 

Crossings

Number of Crossings 

Contributing 

Sediment

Estimated Sediment 

Contribution (tons/year) 

@1.7/tons/yr

Baker 2 2 3.4

Christisen 0 0 0 

Lavene 6 6 10.2

Lloyd 1 1 1.7

Pierce 17 6 10.2

Boulder 2 2 3.4

Piquett 67 47 79.9

East Piquett 18 11 18.7

Violet 9 8 13.6

Ward/Barn Draw 25 21 35.7

Steep/Applebury/Pine 4 3 5.1

West Fork crossings not accounted 

for above 48 9 15.3

Total crossings of the West Fork 199 116 197.2

Subwatershed ECA

(%) 

Total 

Area 

(acres)

Stream Type Number of 

Stream Crossings

Channel 

Condition

Boulder Creek <1 13,664 B3 2 Excellent
Affected Environment and Environmental Consequences - Watershed

3.6-10 Lower West Fork Project Final EIS 

A large portion of the Boulder Creek watershed is wilderness with little to no development. Some timber 

management has occurred in the smaller portion of the watershed outside the wilderness and developments 

include a campground, trailhead, and private home sites. Boulder Creek is a steep, confined, bouldery 

stream type “A” for most of its length but grades into a stream type “B” then stream type “C.” We 

surveyed near the campground and trailhead where the “B”stream type grades to a “C” stream type. 

Boulders give way to cobbles and gravels as the stream types change from “B” to “C” types, respectively. 

Stream conditions are excellent and appear to be functioning within natural parameters. 

In 2006, the Lake of the Rocks Fire burned an estimated 950 acres (about 7%) of the Boulder Creek

watershed. The fire was classified largely as a stand replacement fire that burned at high elevations along 

the south ridge of the watershed. No evidence of debris flows or other fire related episodic erosion events 

occurred during the summer of 2007. There is low to moderate risk that this type of event could occur in 

2008, with a lower risk in 2009. 

The most recent timber management in the Boulder watershed was thinning and hazard tree removal in the 

campground. Sanitation salvage occurred in 1995. Any ground disturbance that was associated with these 

activities has revegetated and is no longer a sediment source. The largest contributor to ECA was the 2006 

fire. ECA is well below the threshold of water yield increases (Table 3.6-3) so the potential is low that 

stream channel morphology would change. 

There are 1.7 miles of road in this watershed, including two road crossings on Boulder Creek (Table 3.6-3). 

One of these crossings is the West Fork highway; the other is a bridge on a native surface forest road

upstream of the West Fork highway crossing. The Forest Service graveled the road approaches to the 

bridge in 2007. Sediment input is low because the road is level at the crossing, and silt fence prevents 

sediment from entering the Creek. 

There are no irrigation withdrawals on this stream. 

Table 3.6-4: Existing Condition of HUC 0303, Piquett Creek 

Piquett Creek, HUC 0303

East Piquett Creek

East Piquett Creek is a major tributary to Piquett Creek that flows from the east. At the lower elevations, 

near private land, the stream is a moderately confined “B” stream type with a short “C” reach just above the 

National Forest boundary. The more sensitive “C” stream reach was surveyed. At this site, the channel 

was at the lower end of the reference range. Parameters such as percent fines were similar to reference but 

the channel stability was slightly lower than reference, which indicates a recovering trend. 

Most timber harvest in this watershed ended in 1988. Limited sanitation/salvage harvest took place on an 

additional 140 acres in 1995. Sediment from harvest activities is likely at pre-harvest levels because 

vegetation has regrown. In 2007, the Rombo Fire burned portions of East Piquett Creek. The burned areas 

were included in ECA calculations. Watershed modeling of the entire burned area (PF-WAT-26) estimates 

a potential sediment delivery to streams of 8.6 tons/acre over the next five years. The Rombo Fire put ECA 

in this watershed well above the threshold for higher water yields (Table 3.6-4), which increases the 

potential for channel morphology changes. 

Twenty-five miles of road have been constructed in the watershed but only 6.9 miles of NFSR 731, the 

main collector road in the drainage, is currently open to full sized motorized vehicles. There are 18 

culvert/stream crossings mapped on East Piquett and its tributaries (Table 3.6-4). The forest road inventory

Stream Name ECA

(%) 

Total 

Area 

(acres) 

Stream Type Number of 

Stream Crossings

Channel 

Condition

East Piquett 34 5,331 C4 18 Good

Piquett 54 20,621 C4 67 Good
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-11 

indicates that most roads are vegetated or stable, and seven culverts do not contribute sediment to streams

(PF-WAT-37). Therefore, these roads and culverts were not included in the sediment contribution 

calculations. The road inventories identified three locations that were contributing sediment: a slumped 

road at a wetland crossing that was no longer usable, and culverts on two tributary stream crossings had 

been removed but the streams banks were unstable and eroding. 

Review of the GIS layers show that diversions of East Piquett Creek occur below the National Forest 

boundary and that water is used to irrigate private land adjacent to Piquett Creek. At low flows, the lower 

end of East Piquett is dewatered enough to impede fish passage.

In summary, although there are sediment contributions from roads, East Piquett is in good condition. There 

are opportunities for road obliteration or storage in the areas with high road densities.

Piquett Creek

Piquett Creek is one of the main tributaries to the West Fork River in the analysis area and flows into the 

river from the south, near Trapper Creek, at the eastern end of the analysis area. At the lower elevations, 

the stream is mostly a moderately confined “B” stream type. The stream survey was located within a short 

“C” reach not far above the road crossing on NFSR 49. The measured parameters are similar to reference 

streams though coarse sands are more common in the substrate than would be expected. Geology and soil 

types appear to be the source of the higher level of coarse sands s because coarse sands are also common in

the unmanaged portions of Piquett and at the lower elevations. 

Most of the timber harvest in this watershed was completed by 1998; the most recent harvest occurred in 

the Castle Creek portion of Piquett Creek. Sediment from these harvest activities is likely at pre-harvest 

levels because vegetation has regrown on the disturbed soils. No harvest has occurred on about one half of 

Piquett Creek watershed. In 2007, the Rombo Fire burned 6,486 acres at moderate to high intensity with 

additional areas burned at low intensity. Erosion and sediment modeling after the fire (PF-WAT-26) 

predicts the potential for 8.6 tons of sediment/acre could be delivered to streams from the entire burned 

area over the next five years. The Rombo Fire put ECA in this watershed well above the threshold for 

higher water yields (Table 3.6-4), which increases the potential for channel morphology changes. 

Road construction during timber harvest created high road densities in portions of the watershed, but large 

areas exist without roads or other development. There are over 67 miles of road mapped in the Piquett 

watershed of which 17 miles are open to highway vehicles. Areas with the highest road densities include a 

small un-named drainage at milepost 2.3. Roads are about 200 feet apart on the hillside because they were 

built for yarding with Idaho Jammers. Some of the roads are vegetated or stable and do not transport 

sediment into streams (PF-WAT-27). Twenty of the 67 culverts did not contribute sediment to streams and 

were not included in the sediment analysis (Table 3.6-4). NFSR 49 is a valley bottom road located against 

the toe of the slope. It has a flat, well-vegetated riparian buffer strip that generally is more than 200 feet 

between the road and the stream. The buffer and gentle road gradient greatly reduce the risk of road 

created sediment entering the stream.

Diversions of Piquett Creek occur below the National Forest boundary to irrigate private land near the 

stream. These withdrawals do not interrupt the flow of Piquet Creek into the West Fork River and fish are 

able to migrate between the two systems, year-round. 

Piquett Creek will likely see some fluctuations in sediment contributions from the Rombo Fire. Modeling 

completed after the Rombo Fire estimated a worst case scenario of 8.6 tons of sediment/acre could be 

delivered to streams over the next five years (PF-WAT-31 and WAT-26). Although not the worst-case

scenario, the erosion event that occurred in July of 2009 did contribute sediment to Piquett Creek and 

downstream reaches. The tributary (or tributaries) where the event occurred will change the most, but the 

additional deposition in the mainstem of Piquett was at levels too low to cause channel changes. 

In summary, Piquett Creek is in good condition. There are opportunities for road obliteration or storage in 

the areas with high road densities. 
Affected Environment and Environmental Consequences - Watershed

3.6-12 Lower West Fork Project Final EIS 

Table 3.6-5: Existing Condition of HUC 0305, Lower West Fork 

Lower West Fork, HUC 0305

Applebury, Pine, and Steep Creeks are three small watersheds in the Lower West Fork hydrologic unit on 

the southeast side of the West Fork River. The access to these drainages is limited and no active 

management has occurred in them the in the past twenty years. There are no proposed activities in these 

watersheds so we do not analyze them further. 

Baker Creek Watershed

Baker Creek watershed is mostly unmanaged. Baker Creek is a steep, bouldery, well confined “A” stream

type. This stream is a reference stream because there has been little management activity on National 

Forest in the watershed. 

The managed portion of the drainage is narrow and mostly classified as Riparian Habitat Conservation 

Area (RHCA). Sanitation/salvage harvest in the mid-1980s occurred on about 156 acres of the watershed. 

This type of treatment does not increase ECA because individual trees are removed which typically reduces 

crown cover less than 10 percent. Sediment sources are few and sediment transport is low because the only 

two stream crossings are located on road sections with gentle gradients (Table 3.6-5). A small amount of 

timber was harvested recently under the Frazier Interface Fuels Reduction project. The Frazier Interface 

Fuels Reduction analysis predicted very low to no sediment contributions from harvest or prescribed fire 

activities. Monitoring confirmed that no sediment crossed into buffers or entered the streams (2006 Forest 

Plan Report, Item 22). 

At the National Forest boundary, a ditch diverts water from North Baker Creek into Frazier Draw below the 

crossing of NFSR 5629 for use on private land. The diversion causes channel damage on private land 

during high stream flows. 

In summary, Baker Creek on National Forest is in very good condition. There are few sediment sources, 

and monitoring of the Frazier Interface Fuels Reduction project indicates that no sediment crossed from 

activity areas into riparian buffers or streams. This watershed and stream are functioning at potential on 

National Forest.

Christisen Creek Watershed

Christisen Creek is a small, lower elevation watershed. A stream survey conducted just above private land 

found the stream to be sandier than reference streams. This is likely due to the geology and soils of the 

watershed because there are no human-caused sediment sources and there has been little timber harvest. 

Approximately 27 acres of salvage harvest occurred within the watershed boundary in 1998 and other 

harvest occurred about 20 years ago. The 1998 harvest was not located near streams so it is very unlikely 

sediment entered the streams. Sediment from these older activities is probably not entering Christisen 

Creek because vegetation growth over the past 20 years has stabilized the soils. There are no road 

Stream Name ECA

(%) Stream Type Number of Stream Crossings

Channel 

Condition

Baker 15 A4 2 Excellent

Christisen 33 A4 0 Good

Lavene 27 A4 6 Good

Lloyd 30 A4 1 Good

Pierce 9 A4 17 Fair

Violet 69 A4 9 Fair/Poor

Ward Cr. Group 11 A4 25 Good

Troy 5 A4 2 Good

West Fork 6 B3 48 Good
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-13 

crossings and only 0.15 mile of road in the Christisen Creek watershed (Table 3.6-5). ECA is estimated at 

33.4%, which is relatively high in this watershed (Table 3.6-5). Unit 82, a pre-commercial thin, is the only 

proposed activity. Pre-commercial thin treatments rarely increase runoff because the residual stand utilizes 

soil moisture. No additional analysis will occur. 

Various diversions remove water from Christisen Creek beginning immediately below the National Forest 

boundary. Christisen Creek flows into a ditch prior to entering the West Fork River; as a result, only a 

small amount of water flows into the river during July, August, and September. 

In summary, Christisen Creek is likely functioning at its potential on National Forest because there are few

sediment sources. 

Lavene Creek Watershed

Lavene Creek is a small, lower elevation watershed. Steep slopes in the headwaters increase the risk of 

erosion following disturbance events. A stream survey on Lavene Creek above private land found the 

measured parameters were similar to the reference stream (PF-WAT-2). 

Most timber harvest in the watershed occurred prior to 1987. Sediment related to these harvest activities 

has recovered. Elliot (2000) found that erosion returns to pre-harvest levels within three to five years of 

harvest. Six stream crossings currently act as sediment sources in the watershed (Table 3.6-5). Existing 

ECA in the watershed is near the 20-25% threshold (Table 3.6-5). 

Lavene Creek flows into a ditch where it crosses into private land, but water does flow into the West Fork 

River at all flow levels. The stream crosses under the West Fork highway and enters the river through a 

perched culvert that does not allow fish passage. 

In summary, channel conditions in Lavene Creek are good. There are few sediment sources and timber 

harvest has been largely sanitation salvage. Timber stands are well stocked, intercept precipitation, provide 

ground cover, and utilize precipitation. 

Lloyd Creek Watershed

Lloyd Creek is a small, lower elevation watershed. Stream surveys above private land indicate measured 

parameters are similar to reference streams (PF-WAT-2). 

Most timber harvest occurred prior to 1986. Sediment sources related to these activities have revegetated 

(Elliot 2000). The current sediment sources are one road crossing and 0.25 mile of road in the watershed 

(Table 3.6-5). 

We estimate ECA at 30% in Lloyd Creek watershed, which is above the 20-25% threshold where water 

yield may increase (Table 3.6-5). Lloyd Creek flows into a ditch after entering private land and then into a 

wetland formed by the highway. This limits the connection and flow of water from Lloyd Creek to the 

West Fork River. 

In summary, Lloyd Creek watershed is in good condition based on the low level of harvest, road densities, 

and channel conditions. 

Pierce Creek Watershed

Pierce Creek watershed is located on the northern edge of the analysis area. A stream survey located above 

private land indicates that Pierce Creek is similar to reference streams (PF-WAT-2). 

Most harvest on National Forest in this watershed was completed by 1986. Sediment sources related to 

these activities have revegetated (Elliot 2000). Recent harvest on private land in Section 28 occurred in 

2005-2006 and included road construction adjacent to Pierce Creek. The effects of this project are 

unknown but no known sediment contributions have occurred. We estimate ECA from past activities is at 

9.4% (Table 3.6-5), which is below the threshold of water yield increases.

NFSR 363 parallels Pierce Creek for about one mile. Prior to recent improvements, this road produced and 

delivered the most sediment during runoff events in the project area. This section of road was graded and 
Affected Environment and Environmental Consequences - Watershed

3.6-14 Lower West Fork Project Final EIS 

graveled in 2004, which greatly reduced the surface erosion. Road sediment contributions have been 

essentially eliminated at all input points since graveling. Maintenance over time will be needed to ensure 

road drainage function. Surfacing roads with gravel reduces sediment production by four to 17 times 

depending upon the quality of the gravel (Foltz 1996). Burroughs and King (1989) found gravel reduces 

sediment by 70-79%. Gravel reduces sediment production by decreasing the length of flow across the road. 

Aggregate and larger sized particles are less likely to be moved than smaller sand sized particles, and the 

compacted gravel surface resists crushing and rutting. Gravel surfacing NFSR 363 reduced rilling and 

thereby reduced sediment production. The road surface has fewer rills, and where they are present, they are 

much shorter in length and carry much less sediment. 

A stream crossing was removed and restored on NFSR 74348. Vegetation regrowth has stabilized the soils 

at the crossing. Field inventories on the road system found that 11 of the 17 crossings were not 

contributing sediment to the streams; these 11 crossings will not be included in current sediment 

contribution calculations. 

Irrigation diversions are located on Pierce Creek below the National Forest boundary. Then Pierce Creek

flows into a wetland created by the West Fork highway, which does not directly connect to the West Fork 

River. 

In summary, Pierce Creek is in fair condition with an improving trend. The road adjacent to the Creek and 

historical harvest levels reduced its condition. However, stream condition is improving because of the time 

since harvest, the culvert removal on NFSR 74348, and the graveling and shaping of NFSR 363. 

Violet Creek Watershed

Violet Creek is located on the east side of the West Fork. Field review indicates this creek only flows into 

West Fork River during very high flows. There may be a subsurface connection but there is no defined 

stream channel entering the river. 

Between 1976 and 1989, 507 acres of harvest occurred in the Violet watershed. Sediment sources related 

to harvest activities have revegetated (Elliot 2000). We estimate ECA is 69% in this watershed, which is 

well above the threshold of increasing water yield (Table 3.6-5). This high ECA is because of the past 

harvest levels and the small size of the watershed. However, field review found Violet Creek is a small 

channel with a substrate composed of coarse gravels and a few cobbles. There were no obvious lengths of 

unstable bank, eroding, headcutting stream channel, or transport of sediment to the West Fork River. 

Riparian vegetation was present and consisted of sod forming grasses and shrubs. 

Eight of the nine stream crossings on Violet Creek were delivering sediment to the Creek (Table 3.6-5). 

The one crossing not contributing sediment was not included in the sediment calculations. In addition to 

the stream crossings, there are 10.6 miles of road in this watershed. Restoration opportunities were

identified in this watershed.

Violet Creek is in fair to poor condition due to road and past harvest influences. Activities such as 

commercial or pre-commercial thinning would improve vegetation conditions and not alter water yields 

because they do not create large openings in the overstory. 

Ward Creek Group 

Ward Creek Group is a cluster of small streams located on the southwest end of the analysis area near the 

West Fork Ranger Station. They were grouped together because they are similar in vegetation type, parent 

material, and past activities. They are small, low elevation streams that flow into wetlands created by the 

West Fork highway before crossing the highway through a culvert and entering the river. Ward Creek is 

the largest stream in this group. Its substrate has more cobbles than most of the other small, low elevations 

streams on the west side of the river. Stream surveys indicate that Ward Creek stream conditions are 

similar to reference. The other named stream in this area is Barn Draw, a small intermittent stream that 

flows during snowmelt or large storm events. A walk-through survey found the defined channel to be steep 

and have a sandy bottom. Barn Draw was channelized and relocated through the West Fork Ranger Station 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-15 

administrative site, and is in poor condition. One small, intermittent, unnamed stream just west of the 

Ranger Station has sections with surface water but no defined channel, and is classified as a wetland, 

ephemeral draw. Other small streams in this group were not surveyed.

Shelterwood, clearcut, and salvage/sanitation harvest have occurred throughout this area, most recently in

2001-2002. Individual tree harvest of beetle-killed Douglas fir occurred around the Ranger Station. 

Salvage of blowdown in the Barn Draw-Ward Creek area occurred in 1995. Sediment sources related to 

these activities revegetated and returned to pre-activity levels (Elliot 2000). ECA is estimated at 11%

(Table 3.6-5), which is relatively low. 

The main sediment sources in this area are roads. The sandy soils are easily erodible. Five of the 25 

crossings in this watershed do not contribute sediment to streams and are not included in the sediment 

analysis. The 20 stream crossings included in the sediment analysis contribute sediment to streams in the 

Ward Creek Group. Sediment contributions to Barn Draw were greatly reduced when one road, a chronic 

source of sediment, was reshaped and graveled in 2006. The fill of the West Fork highway creates ponds 

that streams in the Ward Creek group flow through before entering the West Fork River; sediment is not 

transported to the River. 

An irrigation diversion on Ward Creek is used to irrigate the National Forest pasture and hayfield at Lone 

Pine. 

In summary, most of the Ward Creek group is in good condition, except Barn Draw. Stream channel 

conditions are more strongly influenced by road sediment than from changes in water yield. The poor 

condition of Barn Draw is mostly from channelization and relocation that occurred during the early 

development of the West Fork Ranger Station. 

West Fork Bitterroot River within HUC 0305

Hydrologic Unit 0305 includes the streams discussed above, as well as, several miles of the West Fork 

River and intermittent streams that usually do not flow directly into the river. The West Fork highway 

culvert system creates wetlands and ponds that intercept the intermittent streams. The West Fork River is 

generally a stream type “B” with moderately confined banks and a large cobble substrate. There is a short 

section of low gradient, meandering “C” channel near the West Fork Lodge between Violet and Christisen 

Creek. In the analysis area, the West Fork River is in good condition with low percentages of sand in the 

substrate. Painted Rocks Lake, about eight miles upstream of the analysis area, modifies the flow, 

sediment, and temperature regimes in the West Fork River below the dam. Current dam operations do not 

alter flow in the river in a way that would harm fish or other aquatic life (DEQ 2005) because they augment 

flows during the late summer months and reduce the effects of irrigation withdrawals on the river. The 

Dam maintains cooler water temperatures in the summer when the stored water is released. 

The Restoration Plan recommends managing sediment sources on National Forest roads to reduce 

sediment. We surveyed the West Fork River, below Piquett Creek and above Barn Draw near the West 

Fork Ranger Station, using pebble counts. The percent fines less than 2mm and less than 6mm were well 

below the target set by the Restoration Plan. The d50, the median size particle, was 90mm above Barn

Draw and 71mm below Piquett Creek. The particle size is coarser than the target range of 3-47 mm set in 

the Restoration Plan. Painted Rocks Dam likely traps and holds sediment from the upper West Fork River, 

reducing the amount of smaller sized particles in the river below the dam. Even though pebble counts are 

better than the target set in the Restoration Plan, the West Fork River still requires a TMDL target and 

Restoration Plan because of the lack of macroinvertebrate data needed to evaluate aquatic life, beneficial 

use support, and thermal modification. 

The Restoration Plan lists unstable stream banks along the West Fork River as another source of sediment 

or at risk of erosion. At the time of the Restoration Plan analysis, 8.2% of the stream banks were unstable; 

22.4% of the unstable banks were rated as high to extreme risk of bank erosion and were located mostly on 

private land. 
Affected Environment and Environmental Consequences - Watershed

3.6-16 Lower West Fork Project Final EIS 

Sediment contributions to the stream system from the fires in 2000 are at pre-fire levels because sediment 

sources have revegetated (Elliot 2000). The fires in 2000 burned portions of East Piquett Creek, Piquett 

Creek, and the east side of the West Fork River near Trapper Creek Job Corps. These creeks are tributaries 

of the West Fork River. Approximately 1600 acres burned at high or moderate intensity. The Rombo Fire 

in 2007 burned another 7,300 acres at moderate or high intensity in Piquett Creek and East Piquett Creek

and other areas burned at low intensity. Until soils stabilize and vegetation recovers, in 1-5 years after the 

fire, this burned area presents the largest potential sediment source in Piquett Creek and the West Fork 

River. During intense rainstorms, sediment from this area would be transported into the Piquett and East 

Piquett creek systems and ultimately into West Fork River.

Roads are another sediment source in this watershed. There are 29 miles of road and 48 culverts in this 

watershed that are not included in the previously described watersheds (Table 3.6-5). Most of these roads 

were field reviewed to determine sediment sources and restoration needs. The sediment analysis includes 

nine of the culverts because field review showed that 21 culverts on National Forest and 18 culverts on the 

West Fork highway were not delivering sediment to the streams. Sediment contributions from paved roads 

are usually only associated with snow plowing and sanding operations. The effects of these activities are 

discussed in the cumulative effects analysis. 

Most timber harvest in the West Fork watershed occurred ten or more years ago. Sufficient time has passed 

for sediment sources to revegetate and erosion subside to pre-harvest levels (Elliot 2000). The most recent

timber harvest was the Frazier Interface Fuels project in Frazier Draw. Monitoring found that sediment 

from the harvest or prescribed fire treatments did not cross into buffers or streams (2006 Forest Plan 

Monitoring Report, Item 22). All timber harvest activities are complete in the Frazier Interface Fuels 

project but some prescribed fire units remain. 

About 200 acres of timber harvest occurred on private land (T2N, R21W, Section 28) near Pierce Creek in 

2005 and 2006. This included road construction within the Pierce Creek RHCA. The location of the road 

so near the stream likely contributed some sediment to the creek, but the limited 2005 stream survey did not 

show an increase in sediment deposition that could be attributed to this road. 

The Nez Perce Watershed Improvement Project was implemented in 1997 and 1998 on roads between 

Pierce Creek and Ward Creek (PF-WAT-14). Within the Lower West Fork analysis area, about 24 miles of 

roads on the west side of the river were stored, had a change in season of use, or had sediment sources 

blocked with slash, seeded or mulched. Monitoring these roads in 2005 and 2006 found that closures were 

effective, and sediment sources on roads were well vegetated (PF-WAT-27). 

3.6.5 ENVIRONMENTAL CONSEQUENCES

A. Effects Common to Alternatives 2 and 3

Hauling timber on roads within sediment contributing distance to streams is the largest potential source of 

sediment in this project. Monitoring conducted during restoration activities following the fires of 2000 

supports this conclusion (USDA Forest Service 2003 and 2006) and shows that good timber sale 

administration resulted in far less erosion and sedimentation in 2003 and 2004 than in the first year of 

winter hauling. A study of log hauling effects on wet forest roads (not frozen or dry) found that logging 

traffic produced 2-25 times as much sediment compared to no traffic (Foltz 1996). Contract provisions and 

application of BMPs restrict log hauling during wet periods when the potential for erosion and 

sedimentation are high. Logging traffic on unsurfaced roads increases sediment production by a factor of 

1.9 (Burroughs 1990), and heavy truck traffic results in 2.1 times as much sediment (Burroughs and King 

1989). Sediment from roads could enter streams in the Lower West Fork project area especially on roads 

that parallel streams. Eight tenths of a mile of Pierce Creek, 0.4 mile in Frazier Draw, and 0.3 mile of 

Sedimentation 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-17 

Piquett Creek are vulnerable to sedimentation because these sections of road parallel the streams. The 

other sediment input points are mid- and upper-slope road/stream crossings.

It is very unlikely that log hauling on wet roads would occur project area-wide. If log hauling on wet roads 

were to occur, it could only occur on one to a few sections of road because: 

1) Typically, only one harvest area is active at a time so only a few sections of road would be 

used for hauling. 

2) Spring break-up, which has the highest potential for wet road conditions during log hauling, 

occurs at slightly different times due to elevation and aspect. 

3) The sale administrator or aquatics specialists visit the project area several times each week, 

especially during spring break-up or when conditions are risky. The sale administrator stops 

log hauling when conditions are wet and sedimentation risk is high. 

The Restoration Plan estimated that each road crossing delivered 1.7 tons of sediment to streams (DEQ 

2005). Log hauling under wet conditions could more than double sediment inputs beyond that contributed 

from a road without traffic (Foltz 1996). In small streams, increases of that size could affect stream 

channel conditions and water quality. Timber sale administrators visit sales almost daily during hauling 

operations and are effective in shutting down hauling, especially during early spring when water quality 

violations are probable (USDA Forest Service 2006). The 2006 Forest Plan Monitoring Report, Item 22 

documents the benefit of haul related restrictions and the reduction in risk of sediment contributions to 

streams. It demonstrates that good sale administration and specialist monitoring reduced the risk of stream 

sedimentation from harvest related traffic on wet roads. We expect this level of monitoring and sale 

administration would be applied to this project and achieve similar results.

Resource specialists would monitor, and timber sale administrators would apply and enforce mitigation 

measures during timber sale operations to reduce stream sedimentation from timber harvest activities. 

Examples of these mitigation measures are: 

Ø straw bale check dams above culverts

Ø BMP IV.A.1: limit the operating period of timber sale activities

Ø BMP III.C.7: control road and trail erosion

Ø BMP III.D.6 and IV.B.1: control traffic during wet periods 

Ø BMP III.E.3 and 4 and BMP VI.B.2: control snow removal 

These controls are included as timber sale contract provisions and are a breach of contract when not 

followed. In addition, all haul routes would be maintained commensurate with their use as required by the 

timber sale contract, and would include such things as maintaining drivable dips, cleaning and maintaining 

ditches, shaping road surface to facilitate drainage, and cleaning cross drain culverts. 

Estimates from the Disturbed WEPP model indicate harvest activities would not contribute measurable 

levels of sediment to streams in the analysis area. RHCA buffers, mitigation, project design and the 

application of BMPs would act together to keep sediment from streams. Monitoring conducted on recent 

projects in the East and West Forks of the Bitterroot River support this conclusion (USDA 2003-2006, Item 

22). 

Prescribed fire would occur in both action alternatives. This activity includes manually thinning 

unmerchantable trees - “slashing,” piling the slash in selected units, and burning the piles or underburning 

the stand at low to moderate intensity. Fire would not be ignited in the RHCAs but would be allowed to 

back into the riparian area. This type of fire does not burn all the organic soil material, which maintains the

sponge capacity of the organic layer and protects the soil from sheet erosion (Robichaud 2000). The 

Disturbed WEPP model predicted the probability this treatment would increase sediment in streams ranged 

from 0 to 33%. Monitoring of the Frazier Interface project and other recent, large prescribed fires found 

that the majority of RHCAs do not burn during prescribed fires because of the high moisture content along 
Affected Environment and Environmental Consequences - Watershed

3.6-18 Lower West Fork Project Final EIS 

streams in the spring when prescribed fires are typically lit. Where fires burn into riparian areas, the burn is 

spotty and discontinuous, and rarely burns to the stream. Thus, there is usually a buffer of unburned forest 

between the prescribed burn area and the stream. The buffer intercepts the sediment from the burned areas 

and prevents it from entering the stream (USDA 2006, Item 22; and PF-FISH-7). The risk of prescribed 

fire transporting sediment to streams is relatively low. 

We propose to restore terraces in both action alternatives. RHCA buffers would prevent sediment created 

by this activity from entering streams but the flat, level terraces would also prevent the transport of 

sediment. Should erosion occur, sediment would be caught by the next lower terrace. Restoration 

activities would include decompaction, spreading slash, planting shrubs, sowing seed and fertilizing. These 

activities would improve water infiltration, provide coarse woody material to create sediment traps and soil 

organic matter, and augment revegetation of the exposed soil. The soil capacity to absorb precipitation 

would be enhanced which would further inhibit potential sediment transport. 

We do not expect temporary roads and landings to contribute sediment to streams. These facilities are 

located outside of RHCAs, and do not cross streams. A modeling effort conducted for Middle East Fork 

(PF-WAT-23) predicted that no sediment would enter streams from roads outside of RHCAs. The Lower 

West Fork project is similar to the Middle East Fork project because it has similar soil types and criteria for 

temporary road and landing locations. Therefore, Lower West Fork project effects would be similar. We 

expect that sediment from landings and temporary roads would not enter streams because they would not 

be located in RHCAs and ground cover would be similar. Should the potential for sediment transport 

become apparent during project implementation, straw bales would be placed to trap and filter sediment. 

Temporary roads and landings would be seeded and fertilized after use. 

This project proposes to store or decommission several roads to reduce road density and sediment sources, 

and advance watershed restoration by implementing the Restoration Plan. Roads converted to long-term 

storage would have the following treatment: remove culverts, recontour sections of road adjacent to 

streams, and decompact the rest of the roads. The roads would be seeded, fertilized, mulched, and covered 

with slash as appropriate, and would be available for use in the future. Decommissioned road treatments

would be treated similarly to stored roads, except more of the road prism would be recontoured if funding 

were available. Recontouring unneeded roads is the best long-term treatment because the entire road prism 

is restored to match the adjacent hillslope, the area revegetates better, and sediment sources are eliminated

(Foltz et al. 2007). Decommissioned roads would be taken off the system and no longer available for use. 

Ground disturbance related to road storage and decommissioning often leads to erosion for two to three 

years until vegetation is established on the disturbed ground. Increased sediment transport to streams 

would be expected from roads within 300 feet of a stream or at culvert removal points until soils stabilize 

and the site revegetates. The potential to transport sediment to streams is high during culvert removal and 

replacement because they occur within the active channel. Studies conducted recently on the Nez Perce 

National Forest found that suspended sediment concentrations during culvert removal were highest within 

1⁄2 mile below the culvert and decreased considerably within 800 meters. Culvert removal deposited an

estimated 0.01 to 0.7 ton (20 to 1,400 pounds) of sediment in the stream that would be transported 

downstream during the next high flows (Foltz et al. 2007, and Foltz and Yanosek 2004). One study found 

that sediment deposition averaged about 0.07 ton (140 pounds) at 11 different culvert sites when straw bale 

silt traps installed below the culverts were cleaned before removal (Foltz et al. 2007). This research 

provides strong support for the proper use of straw bales during road storage or decommissioning activities, 

and straw bale placement below culvert removal sites would be included as mitigation with this project. 

Other mitigation of ground disturbance associated with road storage and decommissioning includes seeding 

with annual grasses, mulching, using slash to break up overland flow, and using wattles or erosion control 

mat adjacent to streams. 

Watershed and road restoration can be expensive. However, the costs (Table 3.6-6) are offset by reduced 

risk of culvert failure and associated watershed damage, and improved water quality. Reduced sediment 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-19 

Alternative 1 ~ Potential Impacts on Water

• Increased risk of higher intensity fire 

in areas not treated with fuel 

reduction activities.

• No change in the number of sediment 

contributing points as identified in the 

Restoration Plan and watershed 

inventories. 

• No change in road densities, sediment 

contributions would continue on the 

present trend. 

• No opportunities for improvement. 

contributions mean better fish habitat, less channel deposition, and less effect to downstream irrigation 

systems (pumps and ditches). The costs of decommissioning roads in this project vary depending on 

whether the entire road or sections of the road are recontoured. As stated above, recontouring the entire 

road is preferred when a decommissioned road is not needed for future transportation. However,

recontouring a road segment enhances infiltration and improves vegetation cover at stream crossings. 

Table 3.6-6: Watershed Improvement Cost Estimates on the Lower West Project 

Measurable increases in water yield cause channel adjustments and changes in the channel shape. Visible 

changes include wider channels as channels adjust to hold the higher flows. As channels become wider, 

banks erode and the additional sediment decreases water quality and fish habitat. In areas with high

potential of increasing water yields, controlling all sediment sources is important.

Stream Channel Conditions

The Lower West Fork project was designed to limit ECA increases in sensitive watersheds. Mitigation 

measures were included to prevent declines in water quality and increases in water quantity. 

Though past harvest increased ECA, treated areas have regenerated through natural regeneration and 

planting, and have grown considerably in the past 20 or more years. ECA recovery is influenced by 

elevation, species, and precipitation, which varies by habitat type. ECA recovery is time-dependent; the 

more time passes, the larger trees and shrubs grow, and the more water is used until its use is maximized. 

Recovery curves indicate that ECA of well-stocked stands is 45% in 10 years following clearcut harvest 

(USDA Forest Service 1974). Complete ECA recovery would take close to 100 years. Hydrologic 

conditions in the analysis area were probably not at 100% canopy closure (100% ECA) historically because 

the typical fire regime would have created openings of various sizes. Therefore, 100% ECA recovery is not 

necessary for properly functioning hydrologic systems. 

Stand treatment objectives in this project are to reduce stocking and create small openings to emulate past 

stand conditions under a historical fire frequencies. However, silvicultural prescriptions would create 

limited openings in Lavene, Violet, and Pierce Creek drainages to continue ECA recovery in Pierce Creek 

drainage, and because Lavene and Violet drainages currently have high ECAs. Hydrologic recovery of a 

residual stand is dependent on the health and vigor of the trees for cone and seed production and natural 

regeneration. Therefore, reducing stand stocking and promoting residual tree growth would enhance ECA 

recovery because it would improve conditions for stand 

regeneration. 

B. Direct and Indirect Effects 

In this alternative, there would be no manipulation of 

vegetation or increases in logging traffic, and no road 

storage or decommissioning within the analysis area. 

There would be no change in current sediment sources 

or increase in risk of sediment delivery to streams. 

Channel conditions related to sediment inputs in the 

remaining sub-watersheds would remain on current 

trends. 

Alternative 1

Treatment Cost Estimate

Road Storage $5,000-8,000 per mile 

Road Decommissioning $10,000-12,000 per mile

Additional maintenance on 2 roads to 

eliminate sediment sources $3,900 
Affected Environment and Environmental Consequences - Watershed

3.6-20 Lower West Fork Project Final EIS 

Potential sedimentation from areas burned by 

high intensity fires is much higher than in areas 

that received vegetation and fuels management.

Management Severe Fire 

0 – 5.4 tons/ac. 1.2 – 6.9 tons/ac.

Alternative 2~ Potential Impacts on Water

• Increases in water yield in small 

watersheds with a history of frequent 

harvest activity.

• Low risk of sediment contributions 

from prescribed fire activities

• Risk of sediment contributions from 

hauling on roads adjacent to streams.

• Short –term increases in sediment at 

sites where culverts are removed.

• Long-term decreases in sediment 

contributions from culvert removals 

and road restoration.

• Possible need for herbicide treatment to 

control invasive weeds.

No management actions would occur under this alternative, however, this does not mean that current 

environmental conditions would not change. The risks to watershed resources from a high intensity fire 

would depend on the start of a fire, its location, and size (refer to fuels section 3.3.4). If a large, high 

intensity fire occurs, sediment delivery to streams would increase above current levels. Based on 

observations after the fires in 2000, the risk of debris flows and sediment yield increases would be high in 

some small subwatersheds, depending on the types of storms following the fire. Channel changes and 

longer-term sediment inputs following debris flows in the affected subwatersheds would occur, but the 

effect of these changes on larger downstream catchments would be much smaller and probably not 

measurable. 

Limited estimates of sediment delivery to streams in 

the event of a high intensity fire were calculated for 

this alternative. This information indicates there is a 

slight difference in the magnitude of sediment delivery 

between harvest and prescribed fire treatments, and a

high intensity fire (PF-WAT-19). As expected, the 

model estimated that undisturbed lands result in no 

sediment contributions under average precipitation 

conditions because sufficient ground cover protects 

soils from surface erosion and overland flow. 

Sediment delivery is estimated between 0 and 5.4 tons/acre from lands subject to vegetation and fuels 

management disturbance. The increases in sediment delivery come from prescribed fire and not the cutting 

and yarding of logs. Modeling high intensity fire on the same land types shows sediment delivery increases 

between 1.2 tons and almost seven tons per acre following fire. Based on this modeling and observations 

following the fires in 2000, we can assume that if a high intensity fire occurred in the project area, sediment 

contributions would increase over current levels or those estimated for harvest and fuel reduction activities 

in the action alternatives. 

Sources of Stream Sedimentation 

Alternative 2

Management activities under this alternative would raise 

the risk of sediment delivery to streams. Most of the 

risk comes from higher traffic levels associated with log 

hauling and less risk is associated with timber harvest 

or prescribed fire. Watershed improvements under this 

alternative would offset potential sediment 

contributions from timber management and prescribed 

fire, and would meet the intent of the Restoration Plan

(Table 3.6-2). Both timber management and prescribed

fire would change the amount of ground cover and 

ECA. We do not expect water yields to increase 

enough to modify stream channels because forest cover

in the watershed will not be reduced more than 20-25% 

in most watersheds. 

Road closure and decommission projects in Alternative 

2 would decrease long-term sediment production more 

than would potentially increase from the proposed 

activities. Decompacting or recontouring unneeded 

road prisms, removing culverts at stream crossings, and 

revegetating these areas, would reduce the sediment 

production. 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-21 

There is low sedimentation potential from timber management. Using the Disturbed WEPP model, timber 

management and prescribed fire would have a probability of sediment transport to streams between 0 and 

33%. Monitoring 130 similar units in areas that burned in 2000 and were harvested between 2001 and 

2006, found that sediment from harvest units did not cross into riparian buffers or enter streams (USDA 

Forest Service 2006, Item 22). 

Increased log hauling traffic during wet periods could transport sediment into streams, especially on 

ungraveled stream crossings and roads located within 300 feet of streams as occurs on reaches of Pierce 

Creek, Piquett Creek, and Frazier Draw. In a worst-case scenario, approximately 79 tons of sediment could 

be transported annually to streams from haul roads. This estimate is derived using the methodology 

described in the Restoration Plan (DEQ 2005) and based on the number of contributing haul road stream 

crossings. 

The assumptions upon which the above estimate is based do not reflect current timber management 

practices. The model assumes are that all log hauling would occur on wet roads throughout the year, and 

all stream crossings produce sediment. This, therefore, is a worst-case estimate. The following practices 

would prevent this level of sedimentation: 

1) The timber sale administrator would close roads to log hauling during spring break-up and wet 

periods (FEIS pg. 2-18). 

2) Hauling would not occur on all roads at the same time. Usually, only one part of the sale area 

is open at one time so log hauling would be confined to the open area of the sale. 

3) Application of BMPs would prevent or trap sediment, and keep it from entering streams (FEIS 

pg. 2-18). 

4) The roads that closely parallel streams (Pierce and Frazier), have been graveled. Other haul 

routes do not parallel streams or they are separated from streams by a riparian buffer.

Thus, there is little risk that sediment in streams would increase by the full 79 tons/year. We expect that 

monitoring and sale administration, as described in the 2003 and 2006 Forest Plan Monitoring Reports, 

would be applied during this project (Item 22, and PF-FISH-4, FISH-5, FISH-6, and FISH-8). Monitoring 

would focus especially on small drainages and no log hauling would occur during wet periods. Mitigation 

practices, such as straw bale check dams on haul routes at sediment contributing points would be applied to 

protect streams from additional sediment during hauling operations. 

Stream sedimentation from temporary roads occurs only when the road crosses RHCAs or streams (PFWAT-23). Since no temporary roads would cross or enter RHCAs, we anticipate little to no sedimentation

associated with their use. Table 3.6-7 lists the proposed temporary roads and watershed in which they are 

located. 

Road Management 

In Alternative 2, 18.7 miles of road would be stored and 9.6 miles would be decommissioned (Table 3.6-8) 

removing 22 stream crossings, 16 of which deliver sediment to streams (PF-WAT-27). We estimate 

approximately 0.04 ton (80 pounds) of sediment (1.6 kg at each culvert) would be produced during culvert 

removal (Foltz et al. 2007). The reduction in long-term sediment contributions would offset potential 

short-term contributions of timber harvest, prescribed fire, and culvert removal. 

In the long-term, culvert removal and road storage and decommissioning would reduce sediment by 27 

tons/year and contribute to the eventual de-listing of the sediment impairments in the West Fork River. It 

would meet the intent of the Restoration Plan to reduce sediment from forest roads in the Bitterroot River 

headwaters. 

Implementation of the watershed restoration work would depend upon funding and the individual road 

segments included in the stewardship contract. The proposals included in the stewardship contract (Table 

2-3) would likely be implemented within 5-6 years, before the stewardship contract closed. 
Affected Environment and Environmental Consequences - Watershed

3.6-22 Lower West Fork Project Final EIS 

Table 3.6-7: Proposed Equipment Routes, including temporary roads

Feature Mileage Watershed Unit Accessed

Temp rd, TLM1 trail 0.25 Pierce Unit 1

TLM trail 0.34 Pierce Unit 35

Temp rd 0.25 Pierce Unit 60

TLM trail 0.38 LWF2 Unit 34 

TLM trail 0.17 LWF Unit 3

Temp rd, TLM 0.46 Ward Unit 12

Temp rd, TLM 0.66 LWF Unit 61

Temp rd, TLM 0.30 E. Piquett Unit 41, 99

Temp rd, TLM 0.40 Piquett Unit 16, 89

Temp rd, TLM 0.20 Violet/LWF Unit 20

Temp rd 0.24 Troy/LWF Unit 9

Temp rd, TLM 0.47 Troy Unit 8

 1 TLM (Track-line machine) 

 2. LWF: Lower West Fork

Additional appropriated or partnership funds would be needed to treat those roads not directly tied to the 

timber sale or stewardship contract (optional resource activities). 

Before a road is decommissioned or stored, any vegetation management accessed by the road would need 

to be completed. This makes a “hard” listing of implementation priorities difficult because it is dependent 

upon completion of another project. The following list (Table 3.6-9) combines watershed projects in order 

of priority with the top of the list having the highest priority. The projects are grouped geographically 

where roads near each other are treated at the same time to facilitate the efficient use of equipment, 

materials, and personnel. The priority was determined by the vulnerability of the watershed and not 

necessarily the resource condition. For example, roads causing the most sedimentation are not necessarily 

combined into the highest priority group because that may interfere with access to lower resource priority 

work. Also, it may require repeatedly mobilizing equipment and materials long distances. The priority 

order could change depending on unforeseen factors. The size of each project or group of roads would 

depend upon available funding and could vary from year to year. The intent is to complete the storage and 

decommissioning within ten years of the decision. 

Watershed Restoration Project Priority 

In Alternative 2, the implementation cost estimate of watershed restoration would be between $189,500 and 

$264,800, depending upon the amount of full recontour and the actual contractor bids. Reduced sediment 

contributions translate into better fish habitat, less channel deposition, and less wear on downstream 

irrigation system pumps and ditches. 

Herbicide Treatments

Proposed management activities would create a more open landscape and cause ground disturbance. This 

may provide new areas for noxious weeds colonization. We would treat new populations or species of 

noxious weeds with herbicide to reduce or eliminate them from the project area. Control of noxious weeds 

may cause beneficial or toxic environmental effects. In general, the adverse effects of herbicides are shortterm and localized when applied as spot treatments in a forest setting. Successful eradication or control of

noxious weeds can provide long-term benefits through the restoration of native plant cover, riparian 

function, and other habitat features, and prevention of surface erosion (NFMS 2005).

The analysis focuses on the toxic characteristics of each herbicide proposed for use, the herbicide 

concentrations, and application effects on water quality. This risk analysis tiers to the SBW Weeds DEIS 

(USDA 2008c). The herbicides proposed for use have relatively low aquatic toxicity. An explanation of 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-23 

Table 3.6-8: Stored or Decommissioned Roads under Alternative 2

Road Number Milepost Description** Number of 

Culverts Removed

Number of Contributing 

Culverts Removed

363, Pierce Cr. 5.1-6.8 Storage 0 0 

13411, East Piquett1 1.6-2.4 Storage 4 2 

13411, East Piquett1 2.4-2.8 Decommission 1 0 

13421, Piquett 0.0-0.6 Decommission 0 0 

All Haul Routes1 Entire Length Reshape, maintain drain dips

13422, Piquett 0.0-0.2 Decommission 0 0 

13423, Piquett 0.0-1.7 Storage 1 0 

13423, Piquett 1.7-1.9 Decommission 0 0 

13434, Piquett1 0.0-2.7 Storage 1 1 

13456, East Piquett 0.4-1.6 Storage 0 

13457, Near Baker1 0.0-1.8 Storage 0 0 

13464, East Piquett 1.7-2.3 Decommission 0 0 

13466, Pierce1 0.0-0.6 Storage 3 2 

13828, Troy, 

Lavene 0.0-0.9 Storage 1 1 

13830, Violet1 0.0-1.6 Storage 2 2 

13831, Violet1 0.0-1.3 Decommission 2 2 

13832, Piquett 0.6-0.9 Decommission 0 0 

13834, Piquett 0.0-0.6 Decommission 1 0 

13836, East Piquett1 0.0-2.4 Decommission 2 2 

13838, East Piquett 0.0-0.6 Decommission 1 1 

13883, East Piquett 0.0-0.1 Storage 0 0 

62416, Lavene 0.0-0.6 Storage 1 1 

74006, Ward 0.0-1.2 Decommission 0 0 

74023, Barn Draw 1.0-1.8 Decommission 1 1 

74313, East Piquett 0.0-0.2 Decommission 1 1 

74319, East Piquett 0.0-0.8 Storage 0 0 

74320, East Piquett 0.0-0.2 Storage 0 0 

74339, Castle 0.0-1.7 Storage 0 0 

74347, Pierce 0.0-0.2 Decommission 0 0 

74357, Christisen 0.0-0.3 Decommission 0 0 

74605, Castle 0.0-1.4 Storage 0 0 

74606, Castle 0.0-0.8 Storage 0 0 

74611, Castle 0.0-0.1 Storage 0 0 

13837, 74321 Repair of sediment sources

Total culverts

Estimated Sediment Reduction (1.7tons*16)

22 162

27 tons 1 Included in stewardship contract and completed prior to the contract closure.

2

 BMP work assumed neutral
Affected Environment and Environmental Consequences - Watershed

3.6-24 Lower West Fork Project Final EIS 

Table 3.6- 9: Priority of Watershed Restoration Projects Not Associated With Timber Harvest in 

Alternative 2 of the Lower West Fork Analysis Area

the formulas used to determine the acreages capable of being sprayed with each of the herbicides for the

subwatersheds are in the project file (PF-WAT-32 and 34). NOEL or NOEC represents a conservative 

approach to evaluating the active ingredients of the proposed herbicides within each watershed. The 

acreage capable of being sprayed with each herbicide annually was calculated in each affected HUC – 

without exceeding the lethal amount (LC50/20 or NOEL or NOEC) for trout or salmon (Table 3.7-5). 

Mitigations described in the Fisheries report, Table 3.7-4, would limit herbicide use in RHCAs and 

minimize effects on water quality. 

Alternative 2 proposes to treat up to 300 acres per year, if needed, to control weeds along haul roads, on 

decommissioned and stored roads, or inside of vegetation treatment units. Treatments would occur in 

portions of the analysis area, as needed, where activities occur. They would not be widespread or exceed 

the maximum area allowed for treatment within a hydrologic unit (Fisheries 3.7, Table 3.7-5). 

There are four routes chemicals could enter water: direct application, drift from adjacent treated areas, 

binding to soil that washes into waterbodies, or leaching through the soil. 

Direct application to surface water is not proposed, because it would introduce large quantities of chemicals 

to surface waters, and would cause the most pronounced reduction in water quality. 

Indirect application to surface waters would include drift, overland flow, and leaching. Drift from nearby 

spraying is similar to direct application but concentrations would be lower and the probability of impact 

Road Number Milepost Description** Culverts 

Removed

Contributing 

Culverts Removed

Priority 1

13422, Piquett 0.0-0.2 Decommission 0 0

13423, Piquett 0.0-1.7 Storage 1 0

13423, Piquett 1.7-1.9 Decommission 0 0

13832, Piquett 0.6-0.9 Decommission 0 0

13834, Piquett 0.0-0.6 Decommission 1 0

Priority 2

13883, East Piquett 0.0-0.1 Storage 0 0

74313, East Piquett 0.0-0.2 Decommission 1 1

74319, East Piquett 0.0-0.8 Storage 0 0

74320, East Piquett 0.0-0.2 Storage 0 0

13838, East Piquett 0.0-0.6 Decommission 1 1

13456, East Piquett 0.4-1.6 Storage 0 0

13464, East Piquett 1.7-2.3 Decommission 0 0

13421, Piquett 0.0-0.6 Decommission 0 0

Priority 3

74605, Castle 0.0-1.4 Storage 0 0

74606, Castle 0.0-0.8 Storage 0 0

74611, Castle 0.0-0.1 Storage 0 0

74339, Castle 0.0-1.7 Storage 0 0

Priority 4

74006, Ward 0.0-1.2 Decommission 0 0

74023, Barn Draw 1.0-1.8 Decommission 1 1

74357, Christisen 0.0-0.3 Decommission 0 0

13828, Troy, Lavene 0.0-0.9 Storage 1 1

62416, Lavene 0.0-0.6 Storage 1 1

363, Pierce Cr. 5.1-6.8 Storage 0 0

74347, Pierce 0.0-0.2 Decommission 0 0
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-25 

reduced. Overland flow on bare soils could deliver herbicides to nearby waters. Leaching of herbicides 

through the soil profile is the least likely route for herbicides to enter water. Herbicides can be broken 

down as they move through the soil profile, depending on the type of chemical. 

Most herbicide contamination of water comes from point sources such as spills, leaks, storage, and 

improper handling of equipment or chemicals. These incidents can be avoided through proper storage, 

handling, cleaning, and transport of herbicides and equipment. 

In this analysis, we evaluated the entire herbicide application on individual watersheds as if the noxious 

weeds would be sprayed continuously in the proposed areas in one day instead of over one to two months. 

Continuing with the worst-case scenario, we used the lowest streamflow typical of the specific watersheds 

to determine maximum concentration of herbicides within the streams. In reality, the treatments would 

occur between May and August when flows are higher. Streamflow data was calculated using Embry’s 

(1981) water yield formula; his equation was used to calculate the average cubic feet per second (cfs) of 

water yield for a seven-day, two-year low flow during September, typically the period of lowest flows (PFWAT-32). 

Other assumptions used in evaluate water quality include:

Ø Treatment of all potential sites within the same year.

Ø The picloram application rate of 1.0 pounds of active ingredient per acre corresponds to 4 pints 

of liquid picloram per acre. This is the current maximum recommended rate; in most cases, a 

lesser amount would actually be used. 

Ø All areas would be treated with herbicides. In reality, only a portion of the proposed 300 acres 

per year would be sprayed in each watershed; 300 acres in entire project area is the maximum 

area that would be sprayed. 

Table 3.7-5 in the Fisheries Section, displays the maximum area that could be treated annually in each 

HUC. For most of the herbicides, the proposed annual treatment is 300 acres, well below the maximum 

allowable area. Adverse impacts on surface water quality would be avoided by staying below the 

maximum allowable treatment area, following mitigation measures, using herbicides properly, and 

applying environmental control measures. However, application of Picloram or Roundup, could not exceed 

the maximum annual application. It is unlikely that any herbicide would be detected in stream water from 

the proposed herbicide applications. The method of application and low level of herbicide use spread over 

two or more months relative to the higher water yields during the same period would prevent herbicide 

from entering streams or would dilute potential drift to undetectable levels. 

For example, the spraying of picloram – applied under similar conditions as the proposed action – was 

monitored along a streamside in Montana (Watson et al. 1989). In this study, no herbicide was detected in 

the stream at one part per billion. Application of site-specific Best Management Practices (Appendix A) 

and implementation of project design measures (Chapter 2) would further reduce the likelihood of 

herbicide being detected in stream waters.

Field studies of herbicide spray operations show that herbicide application to streams ranges from nondetectible to 6% of the amount applied (Monnig 1988). 

Rice (1990) reviewed numerous studies of picloram runoff into streams. These studies found that a 

maximum of ten percent of the herbicide applied to a runoff-dominated site could reach a stream within 6 

hours of a heavy rainfall event. On infiltration-dominated sites, they found a maximum of one percent of 

the applied herbicide could reach a stream within 24 hours of a heavy storm. Rice’s assessment 

methodology was used in the aquatics effects analysis. For cumulative effects, it was assumed that 

chemical from all of the upstream treatment sites would reach the same stream at the same time. This 

worst-case scenario is extremely unlikely.
Affected Environment and Environmental Consequences - Watershed

3.6-26 Lower West Fork Project Final EIS 

In summary, herbicide applications would not decrease water quality because of the limited potential area 

of treatment, mitigation measures controlling herbicide application near waterbodies, the types and 

amounts of herbicides proposed for use, and timing of herbicide application (Monnig 1988, Watson et al.

1989). In streams smaller than those identified above, we do not expect herbicide concentrations to reach 

NOEL/NOEC levels. Application of the environmental protection measures (Chapter 2), including proper 

use of herbicides, would prevent adverse impacts on surface water quality. None of the 303(d) streams is

listed because of volatile organic compounds or petrochemicals, and proposed weed control activities 

would not risk exacerbating existing impairment conditions. By following the Environmental Protection 

Measures, label directions, and BMPs, beneficial uses would be supported in all the streams within the 

project area.

Herbicide application is not expected to alter the hydrologic regime or adversely affect riparian or wetland 

habitats. We do not expect to cause measurable changes to peak or base flows, or water or sediment yield. 

The proposed treatments would not cause any large-scale changes in land cover. 

A portion of the herbicides applied to and persisting in these soils may migrate down to shallow 

groundwater; however, the impacts would be minor, short-term, and localized to application areas. The 

project design measures (Chapter 2), would also help prevent “overloading” herbicides in the soil and thus 

groundwater, especially since most herbicide application would be limited to once per year. Very rarely, a 

treatment may occur twice annually, at least 30 days apart. Herbicide effects to groundwater would not 

exceed human health standards (USDA Forest Service 2008, Section 3.8.3). 

Long-term beneficial effects from reducing noxious weeds and maintaining desirable native vegetation 

would be improved watershed conditions. Beneficial effects are expected from the reduction of invasive 

weeds encroaching into riparian areas, wetlands, and streams. 

Effects by 6th Order HUC 

In the following sections, we discuss the environmental effects of Alternative 2 by sixth order hydrologic 

unit. Table 3.6-10 through Table 3.6-12 display subwatershed conditions following Alternative 2

treatments in the specific HUC.

The prescribed fire proposed in the Boulder Creek watershed would not transport sediment into the stream. 

The RHCA between the stream and the proposed burn unit is flat and it would trap sediment transported 

from the unit before it reaches the stream. Monitoring of similar activities verifies that RHCAs are 

effective buffers (2003-2006 Forest Plan Monitoring Reports, Item 22). 

Table 3.6- 10: Condition of HUC 0302, Boulder Creek, Following Treatment

Boulder Creek, HUC 0302 

No temporary roads or landings would be constructed in this watershed. 

The increase in ECA and the associated water yields is well below the 20-25% levels (PF-WAT-15, 

Stednick 1995) so project activities would not lead to changes in channel shape or increase bank erosion. 

In summary, the Boulder Creek stream channel would not change under Alternative 2. This Alternative 

would comply with the Restoration Plan and the Clean Water Act because any sediment contributions

would not be measurable and not change the channel configuration. 

Subwatershed

Existing ECA 

(acres)

(% ECA)

Additional ECA 

(acres)

(% ECA)

Sediment from Prescribed 

Fire (tons)

(Probability of Input)

Number of culverts removed

Long-Term Sediment 

Reduction (tons/year)

Boulder Creek 109

<1

6

<1

0.9

7 0 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-27 

Table 3.6-11: Condition of HUC 0303, Piquett Creek, Following Treatment

Piquett Creek, HUC 0303

East Piquett Creek

The Disturbed WEPP model predicted no sediment would be contributed from harvest activities or terrace 

restoration. Prescribed fire would contribute an estimated 5.7 tons of sediment to streams, but we expect 

sediment contributions would not be measurable based on monitoring of similar projects (PF-FISH-7). 

There would be 0.25 mile of temporary road or tract-line machine (TLM) trail constructed to yard logs. 

These would be located at mid-slope or on the ridge between East Piquett and Piquett Creeks. They would 

not contribute sediment to streams because they would be constructed well away from the RHCA and 

would not cross it. The temporary road and TLM trail would be restored after use by decompaction, 

recontouring, seeding, and fertilizing.

Nine culverts would be removed, including six that deliver sediment to the stream (Table 3.6-11). Culvert 

removal would deliver about 0.02 (20 pounds) of sediment to streams in the short-term, but this would be 

offset by long-term sediment reduction of 10.2 tons. Culvert removals would comply with the Clean Water 

Act because BMPs would be applied. 

The existing ECA estimates include openings created by the 2007 Rombo fire that affected a considerable 

part of the watershed (Fig. 3.5-1). The ECA is higher than the threshold at which stream channel changes 

may be observed and water yield increases may contribute to channel changes in East Piquett Creek. 

Alternative 2 would cause a slight increase in ECA (1%). The risk of channel changes in East Piquett 

Creek is low to moderate and the effects of implementing Alternative 2 would be indistinguishable from 

the Rombo fire effects. 

Piquett Creek

The Disturbed WEPP model predicted no sediment would be contributed from timber harvest activities or 

terrace restoration. The model predicted prescribed fire would contribute about 8 tons of sediment to 

streams. However, based on monitoring results of recent past projects (PF-FISH-7), we expect sediment 

contributions to be lower and not measurable in Piquett Creek. 

Units 16 and 89 would require 0.4 mile of temporary road and TLM trail. Neither the road nor TLM trail 

would enter the RHCA. They would not contribute sediment to streams because of the distance between 

the road and streams, lack of crossings or construction in RHCAs, and restoration (decompaction, 

recontouring, seeding, fertilizing, and slashing) after use.

Three culverts would be removed, including one that delivers sediment to the stream (Table 3.6-11). 

Culvert removal would deliver about 0.005 ton (10 pounds) of sediment to streams in the short-term, but 

the long-term sediment reduction would offset this contribution after the sites recover. The culvert 

removals would comply with the Clean Water Act because BMPs would be applied during implementation. 

They would also be consistent with the Restoration Plan because there would be fewer sediment 

contribution points and less sediment would enter the stream from the road system. 

Subwatershed

Existing ECA

(acres) 

(% ECA)

Additional ECA

(acres) 

(% ECA)

Sediment from 

Prescribed Fire (tons)

(Probability of Input) 

Number of culverts removed

(Long-term Sediment 

Reduction (tons/year)) 

East Piquett 1,829

(34%)

27

(35%)

5.7

(0-3%)

9 Removed, 6 Contributing

(-10.2)

Piquett, excluding 

East Piquett

9,306

(61%) 

32

(61%) 

8.0

(13-30%) 

3 Removed, 1 Contributing

(-1.7) 

Piquett including East 

Piquett 

11,134

(54%) 

59

(54%) 

8.0

(13-30%) 

12 Removed, 7 Contributing

(-11.9) 
Affected Environment and Environmental Consequences - Watershed

3.6-28 Lower West Fork Project Final EIS 

Though we do not expect measurable sediment from project activities to enter East Piquett Creek, any 

sediment that reached that stream could eventually be transported to Piquett Creek because East Piquett 

Creek is a tributary to Piquett Creek. Any sediment transported to Piquett Creek would be less than the 

total sediment delivered to East Piquett Creek because some of the sediment would be stored in East 

Piquett Creek substrate and floodplain. The sediment would be transported gradually and not in one pulse. 

Substrate monitoring in the East Fork following the fires in 2000 attempted to track sediment from 

upstream sources in downstream reaches. The monitoring found that in-channel deposition was difficult to 

measure in the substrate even though known sediment producing events were observed (2004 Forest Plan 

Monitoring Report, Item 17). Low intensity fires, as in the proposed prescribed fire, have a lower potential 

to produce sediment than high intensity fires such as occurred in the East Fork. We expect that sediment 

from both East Piquett and Piquett Creeks would not be large enough to cause channel configuration 

changes in Piquett Creek. 

The existing ECA estimates include openings created by the 2007 Rombo fire that affected a considerable 

part of the watershed. ECA in the Piquett Creek (not including East Piquett) subwatershed is 61%, 36% 

over the threshold at which stream channel changes may be observed. The Piquett Creek subwatershed has 

a moderate risk of water yield increases causing stream channel changes. Alternative 2 would not increase 

ECA. 

It is unlikely that the sediment deposited by the erosion event in 2009 would have an effect on the activities 

proposed by Alternative 2 for two reasons. First, the erosion event occurred upstream of proposed 

activities and second, by the time any activities are implemented, sediment would have been transported 

downstream out of the planning area. 

In summary, timber management and prescribed fire are not expected to cause measurable sediment 

increases in Piquett Creek beyond that resulting from the Rombo Fire, however the watershed is vulnerable 

to water yield increases and channel configuration changes. The potential for sediment contributions from 

the Rombo Fire is moderate to high, depending upon weather over the next 2-3 years. The low to nonexistent sediment contributions from the proposed activities would be indistinguishable from the fire 

sediment contributions. 

Information presented in Table 3.6-12 highlights the sensitivity of Lavene and Violet Creeks in the larger 

Lower West Fork watershed. These streams are sensitive because of the level of past activity and current 

channel conditions, as measured by stream surveys. In these streams, it was important to determine 

changes from the proposal to evaluate effects on the channels. Timber management activities and terrace 

restoration did not contribute any sediment beyond natural levels as modeled using Disturbed WEPP. 

These activities do not increase stream sediment because of how the project is designed, the use of RHCAs 

as buffers between activity areas and streams, and the mitigation measures applied to specific sediment 

sources. 

Lower West Fork, HUC 0305 

There would be approximately 3.12 miles of temporary road, existing skid trail, new temporary road, and 

new track line machine trail constructed to yard logs from the units. These roads and trails would be 

located on ridges or midslope and would not enter RHCAs. They are located more than 300 feet from 

streams, and lack crossings or construction in RHCAs. They are not expected to contribute sediment to 

streams (PF-WAT-23). Restoration (decompaction, recontouring, seeding, fertilizing, and slashing) would 

occur after use. 

Modeling the effects of prescribed fire indicates that sediment could be transported to streams in the Pierce 

and Lavene subwatersheds. These subwatersheds are of concern because of their small channel size and

the level of past activities. In Lavene Creek, prescribed fire is proposed in a steeper area bisected with 

springs and headwater streams. The buffering effect of the RHCA may be inadequate to prevent sediment 

from reaching the streams and wetlands, which may cause channel adjustments. Pierce Creek is on the 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-29 

point of recovering from past activities and the area of prescribed fire is large relative to the size of the 

watershed and estimated sediment levels. The RHCA buffer would be increased to 300 feet in prescribed 

fire units 32, 33, and 60A to provide additional protection to Pierce and Lavene Creeks. Though fire may 

back down into these buffers, it would not burn to the stream channel because of the wet soils and 

vegetation during the spring burning window. Monitoring shows riparian buffers effectively prevent or 

reduce sedimentation from prescribed fire. 

Table 3.6-12: Condition of HUC 0305, Lower West Fork, Following Treatment

Estimated sediment inputs from prescribed fire activities would not be high enough to cause channel 

adjustments in other drainages of this watershed because of soil types, unit locations, and slope steepness. 

Prescribed fire project monitoring (PF-FISH-7), indicates limited burning occurs in the RHCA because of 

the high moisture content in RHCAs during spring when most prescribed fires are ignited. Burning in 

RHCAs is typically a backing fire, where fire ignited on the upland sites creeps into the RHCA. 

Monitoring has shown that sediment contributions would be much lower than modeled and not measurable

in the stream channel because of the very low burn intensity and the discontinuous burn pattern (2006 

Forest Plan Monitoring Report, Item 22 and PF-FISH-7). 

ECA increases in Pierce Creek, Troy Creek, and the lower West Fork hydrologic unit are estimated to be 

low and remain below the 20-25% threshold. There would be no changes to channel configuration in these 

streams systems from increased water yield. Terrace restoration would occur in the Pierce Creek 

subwatershed. No sediment would be produced from this activity because the flat slope of the terrace 

would limit sediment transport and if it did occur, it would be captured on the next lower terrace or the 

RHCA.

The Violet Creek watershed is well above the ECA threshold with an estimated ECA of 69%. Evaluation 

of the stream channel found the channel was stable and there was no evidence of unstable banks or 

downcutting typically caused by high water yields. The channel is stable despite of the high ECA because 

Violet Creek watershed receives relatively low precipitation and the existing vegetation uses enough of the 

soil moisture to prevent large runoff events that lead to changes in channel features. The increase in ECA 

in Alternative 2 is less than one percent (0.7) and not likely to cause channel changes in Violet Creek. 

Troy Creek is a small intermittent stream with a large amount of thinning from below proposed in the 

watershed. Though a large portion of the watershed is proposed for treatment, the reduction in canopy 

would be low and the residual stand would be stocked well enough to utilize the soil moisture. Alternative 

2 would increase ECA only slightly in Troy Creek, and would not result in changes to the stream channel. 

In summary, the effect of timber management and prescribed fire proposed in Alternative 2 would not 

cause measurable increases in sediment in any of the streams in the Lower West Fork hydrologic unit, 

except possibly Lavene Creek. Wider RHCA buffers in Lavene Creek would mitigate would sediment 

Subwatershed

Existing ECA

(acres)

(% ECA)

Additional ECA 

(acres)

(% ECA)

Sediment from Prescribed 

Fire (tons)

(Probability of Input) 

Number of culverts 

removed

(Long-term Sediment 

Reduction (tons/year))

Pierce 120

(9) 

40

(13) 

7.9

(0-27%) 

3 Removed, 2 Contributing

(-3.4) 

Lavene 352

(27)

14

(28)

6.1

(0-23%)

1 Removed, 1 Contributing

(-1.7)

Troy 25

(5) 

28

(11) 

0.8

(10-17%) 

1 Removed, 1 Contributing

(-1.7) 

Violet 507

(69)

6

(70)

1.7

(3-33%)

4 Removed, 4 Contributing

(-6.8)

Lower West Fork

HUC 

2,078 

(6) 

117

(6)

0.6

(10-23% excluding streams 

accounted for)

2 Removed, 2 Contributing

(-3.4) 

Total: 22, 16 Contributing
Affected Environment and Environmental Consequences - Watershed

3.6-30 Lower West Fork Project Final EIS 

Alternative 3 ~ Potential Impacts on Water

Increases in water yield in small watersheds 

with a history of frequent harvest activity.

Low risk of sediment contributions from 

prescribed fire activities

Risk of sediment contributions from hauling 

on roads adjacent to streams.

Short –tern increases in sediment at sites 

where culverts are removed.

Long-term decreases in sediment contributions 

from culvert removals and road restoration.

No treatment of invasive weeds.

transport to streams and the risk of measurable sedimentation would be low. The overall effect of 

Alternative 2 on the watershed resource would be long-term improvement. There would be a low risk of 

sediment contributions to tributary streams from the prescribed fire proposals. However, we expect the 

amounts of contributed sediments to be less than that predicted by the Disturbed WEPP model based on 

monitoring results of similar projects on the Sula and West Fork Ranger Districts. 

Herbicide treatments are not included in Alternative 3.

Alternative 3

The effects of timber management and prescribed fire, and 

the assumptions in the analysis of effects would be the 

same as in Alternative 2. The differences in effects 

between Alternatives 2 and 3 would be by location and 

intensity. Generally, watershed resource effects would be 

less under Alternative 3 than Alternative 2 because there 

would be less harvest and prescribed fire on the East side 

of the West Fork River. Terrace restoration and more road 

storage and decommissioning would occur on the east side 

of the River, which would reduce long-term sediment

input and implement the Restoration Plan. 

Harvest and prescribed fire activities on the west side of 

the river would be the same as in Alternative 2 with some 

additional road storage and decommissioning. The effects 

of temporary roads would be similar to Alternative 2 on 

the west side of the West Fork River. There would be no 

temporary roads on the east side of the River so there 

would be no effects associated with their use. Logging traffic would be less, especially on the east side of 

the River, under Alternative 3 so the risk of road sediment transport to streams would be lower. 

We do not expect the amount of sediment produced to change channel conditions in the West Fork River. 

The West Fork River is a large stream capable of transporting moderate amounts of sediment without 

changes in substrate conditions and many of the affected tributaries are not connected to the River. 

Sources of Stream Sedimentation 

Road closure and decommissioning activities in Alternative 3 would cause long-term decreases in sediment 

contributions that would exceed potential increases in sediment from the proposed timber management and 

prescribed fire. The probability of sedimentation from timber management would be between 0 and 7% 

based on Disturbed WEPP modeling. Table 3.6-13 lists the proposed temporary roads and watershed in 

which they are located.

Pierce Creek, Frazier Draw and streams with native surface crossings (i.e. not graveled or paved) would be 

susceptible to sedimentation during log haul, especially if log haul occurred when roads were wet. If all 

roads are used for log hauling during spring breakup or heavy storm periods, it is possible that sediment 

delivery could reach 46.7 tons/year, based upon the methodology used in the Restoration Plan. The risk of 

this amount of sediment reaching the streams would be very low because sale administration and 

monitoring would recognize sensitive conditions and stop log hauling before damage occurred. These 

actions would prevent or reduce sedimentation (2003 and 2006 Forest Plan Monitoring Report, Item 22). 

Straw bale check dams and other mitigation measures would filter sediment before it could enter the 

stream. We expect the same level of monitoring and sale administration would be applied to this sale as

those reported on in the 2003 and 2006 monitoring reports. 

Stream sedimentation from temporary roads occurs only when the road crosses RHCAs or streams (PFWAT-23). We anticipate little to no sedimentation associated with their use since no temporary roads 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-31 

would cross or enter RHCAs. No movement of sediment off-site and no sediment delivery to streams were 

found during monitoring of temporary roads in the areas that burned in 2000 (2006 Forest Plan Monitoring 

Report, Item 22). All temporary roads, including old road prisms, would be recontoured, seeded, fertilized, 

and slashed after use. 

Table 3.6-13: Proposed Equipment Routes, including temporary roads, in Alternative 3

Feature Mileage Watershed Unit Accessed

Temp rd, TLM1 0.25 Pierce Unit 1

TLM trail 0.34 Pierce Unit 35

TLM trail 0.38 Pierce Unit 34

TLM trail 0.17 LWF Unit 3

Temp rd, TLM 0.46 Ward Unit 12

Temp rd, TLM 0.66 LWF Unit 61

TLM 0.20 Piquett Unit 89

Temp rd 0.24 Troy/LWF Unit 9

Temp rd, TLM 0.47 Troy/LWF Unit 8 1 TLM - Track-line machine trail 

Road Management 

Under Alternative 3, 18.1 miles of road would be stored and 26.8 miles would be decommissioned, which 

would remove 33 stream crossings, 23 of which contribute sediment to streams (PF-WAT-27). These 

activities would reduce the number of sediment sources, improve vegetation growth on decompacted roads, 

reduce road densities, and store roads in areas burned by the Rombo fire. Sediment would be reduced by 

approximately 39.1 tons/year project area wide (Foltz et al. 2007). Table 3.6-14 displays the roads that 

would be stored or decommissioned under Alternative 3. The reduction in long-term sediment delivery

would offset potential short-term sediment contributions of timber harvest and prescribed fire or culvert 

removal, and lead to the long-term improvement of channel conditions in affected tributaries. 

In the long-term, culvert removal and road storage and decommissioning would reduce sediment by 39.1 

tons/year and contribute to the eventual de-listing of the sediment impairment in the West Fork River. 

Alternative 3 would reduce long-term sediment by 12 tons/year more than Alternative 2. It would meet the 

intent of the Restoration Plan to reduce sediment from forest roads in the Bitterroot River headwaters. 

Implementation of watershed restoration work would depend on funding and the road segments included in 

the stewardship contract. Watershed restoration work included in the stewardship contract would be 

similar to the restoration work included under Alternative 2 and would likewise take 5-6 years to complete 

(Table 2-4). Appropriated or partnership funds would be needed to complete the proposals not included in 

the stewardship contract. It would take longer to complete all the restoration work under this Alternative 

because there is more road storage and decommissioning proposed than under Alternative 2. 

Costs to implement the watershed restoration in Alternative 3, would range between $358,500 and 

$466,400, depending on the amount of recontouring needed and contractor bids. Reduced sediment 

contributions translate to better fish habitat, less channel deposition, and contribute to eventual de-listing of

the West Fork River. 

The same process for setting priorities in Alternative 2 for watershed restoration work not associated with 

the timber sale was used in Alternative 3. The following list (Table 3.6-15) combines watershed projects in 

order of priority with the top of the list having the highest priority. The priority order could change 

depending on unforeseen factors. The size of each project or group of roads would depend upon available 

funding and could vary from year to year. The intent is to complete the storage and decommissioning 

within ten years of the decision. 

Watershed Restoration Project Priority 
Affected Environment and Environmental Consequences - Watershed

3.6-32 Lower West Fork Project Final EIS 

Table 3.6-14: Stored or Decommissioned Roads under Alternative 3

Road Number Milepost Description** Culverts 

Removed

Contributing 

Culverts Removed

363, Piquet Cr. 5.1-6.8 Storage 0 0

363, West Fork near Baker Cr. 0.0-3.0 BMP Improvements 0 0

5724, Piquett 0.0-3.7 BMP Improvements 0 0

13411, East Piquett1 1.6-2.4 Storage 4 2

13411, East Piquett1 2.4-2.8 Decommission 1 0

13421, Piquett 0.0-0.6 Decommission 0 0

All Haul Routes Entire 

Length

Reshape and maintain drain dips; under

contract and complete before contract closes

13422, Piquett 0.0-0.2 Decommission 0 0

13423, Piquett 0.0-1.7 Storage 1 0

13423, Piquett 1.7-1.9 Decommission 0 0

13424, Piquett1 0.2-3.1 Decommission 4 2

13430, Piquett 0.0-4.2 Decommission 1 1

13434, Piquett 0.0-2.7 Storage 1 1

13434, Piquett 2.1-2.7 Decommission 1 1

13456, East Piquett 0.4-1.6 Storage 0 0

13457, Near Baker1 0.0-1.8 Storage 0 0

13464, East Piquett 1.7-2.3 Decommission 0 0

13465, East Piquett 0.0-1.6 Decommission 1 1

13466, Pierce1 0.0-0.6 Storage 3 2

13828, Troy, Lavene 0.0-0.9 Storage 1 1

13829, Violet 0.0-3.6 BMP Improvements 0 0

13830, Violet1 0.0-1.6 Storage 2 2

13831, Violet1 0.0-1.3 Decommission 2 2

13832, Piquett 0.6-0.9 Decommission 0 0

13834, Piquett 0.0-0.6 Decommission 1 0

13836, East Piquett1 0.0-2.4 Decommission 2 2

13837 Repair sediment sources

13838, East Piquett 0.0-0.6 Decommission 1 1

13839, Piquett 0.6-0.8 Decommission 0 0

13840, Piquett 0.0-1.8 Decommission 1 0

13841, Piquett 0.0-1.2 Decommission 1 0

13842, Piquett 0.0-1.3 Decommission 1 1

13883, East Piquett 0.0-0.1 Storage 0 0

62416, Lavene 0.0-0.6 Storage 1 1

74006, Ward 0.0-1.2 Decommission 0 0

74023, Barn Draw 1.0-1.8 Decommission 1 1

74313, East Piquett 0.0-0.2 Decommission 1 1

74319, East Piquett 0.0-0.8 Storage 0 0

74320, East Piquett 0.0-0.2 Storage 0 0

74321, Piquett1 0.0-0.7 Decommission 1 1

74339, Castle 0.0-1.7 Storage 0 0

74347, Pierce 0.0-0.2 Decommission 0 0

74357, Christisen 0.0-0.3 Decommission 0 0

74605, Caste 0.0-1.4 Storage 0 0

74606, Castle 0.0-0.8 Storage 0 0

74611, Castle 0.0-0.1 Storage 0 0

Total culverts removed

Estimated Sediment Reduction (1.7tons*23)

33 232

39.1 ton less 1 Included in stewardship contract and completed prior to the contract closure. 2 BMP work assumed neutral
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-33 

Table 3.6- 15: Priority of Watershed Restoration Projects Not Associated With Timber Harvest in 

Alternative 3 of the Lower West Fork Analysis Area

Effects by 6th Order HUC 

In the following sections, we discuss the environmental effects of Alternative 3 by sixth order hydrologic 

unit. Table 3.6-16 and Table 3.6-17 display subwatershed conditions following Alternative 3 treatments in 

the specific HUC.

Road Number Milepost Description** Culverts 

Removed

Contributing 

Culverts Removed

Priority 1

363, West Fork near Baker Cr. 0.0-3.0 BMP Improvements 0 0

Priority 2

5724, Piquett 0.0-3.7 BMP Improvements 0 0

74321, Piquett1 0.0-0.7 Decommission 1 1

13422, Piquett 0.0-0.2 Decommission 0 0

13423, Piquett 0.0-1.7 Storage 1 0

13423, Piquett 1.7-1.9 Decommission 0 0

13430, Piquett 0.0-4.2 Decommission 1 1

13434, Piquett 0.0-2.7 Storage 1 1

13434, Piquett 2.1-2.7 Decommission 1 1

13829, Violet 0.0-3.6 BMP Improvements 0 0

13832, Piquett 0.6-0.9 Decommission 0 0

13834, Piquett 0.0-0.6 Decommission 1 0

13839, Piquett 0.6-0.8 Decommission 0 0

13840, Piquett 0.0-1.8 Decommission 1 0

13841, Piquett 0.0-1.2 Decommission 1 0

13842, Piquett 0.0-1.3 Decommission 1 1

Priority 3

13883, East Piquett 0.0-0.1 Storage 0 0

74313, East Piquett 0.0-0.2 Decommission 1 1

74319, East Piquett 0.0-0.8 Storage 0 0

74320, East Piquett 0.0-0.2 Storage 0 0

13838, East Piquett 0.0-0.6 Decommission 1 1

13456, East Piquett 0.4-1.6 Storage 0 0

13464, East Piquett 1.7-2.3 Decommission 0 0

13465, East Piquett 0.0-1.6 Decommission 1 1

13421, Piquett 0.0-0.6 Decommission 0 0

Priority 4

74605, Castle 0.0-1.4 Storage 0 0

74606, Castle 0.0-0.8 Storage 0 0

74611, Castle 0.0-0.1 Storage 0 0

74339, Castle 0.0-1.7 Storage 0 0

Priority 5

74006, Ward 0.0-1.2 Decommission 0 0

74023, Barn Draw 1.0-1.8 Decommission 1 1

74357, Christisen 0.0-0.3 Decommission 0 0

13828, Troy, Lavene 0.0-0.9 Storage 1 1

13828, Troy, Lavene 0.0-0.9 Storage 1 1

62416, Lavene 0.0-0.6 Storage 1 1

363, Pierce Cr. 5.1-6.8 Storage 0 0

74347, Pierce 0.0-0.2 Decommission 0 0
Affected Environment and Environmental Consequences - Watershed

3.6-34 Lower West Fork Project Final EIS 

The activities proposed in Boulder Creek would be the same as in Alternative 2. Please see that section for 

discussion on effects. In summary, sediment delivery to streams would not be measurable and Boulder 

Creek channel configuration would not change under Alternative 3. Management activities under 

Alternative 3 would comply with the Restoration Plan and the Clean Water Act. 

Boulder Creek, HUC 0302 

Table 3.6- 16: Condition of HUC 0303, Piquett Creek, Following Treatment

Piquett Creek, HUC 0303 

East Piquett Creek

Commercial thinning in East Piquett Creek would occur as part of the terrace restoration under this 

alternative. No sediment would be produced from terrace restoration as estimated in the Disturbed WEPP

model. However, prescribed fire would contribute 0.5 ton (1,000 pounds) of sediment to streams (Table 

3.6-16). Monitoring indicates that sediment is unlikely to leave treatment units and enter streams (PFFISH-7). 

Though 12 fewer acres of ECA are created in Alternative 3 than in Alternative 2, the effects of treatments 

under this alternative are the same as in Alternative 2. The risk of water yield increases changing channel 

configuration in East Piquett Creek would remain low to moderate until openings created by the Rombo 

Fire revegetate.

In summary, the effect of terrace restoration, burning, and road storage and decommissioning would not 

cause measurable increases in sediment in East Piquett Creek. After the implementation of the restoration 

activities, sedimentation would be reduced and long-term improvements in channel conditions would be 

greater than under Alternative 2. The reduction in road sediment transport would contribute to removal of 

the sediment impairment from the West Fork River. 

Piquett Creek

Commercial thinning in Piquett Creek would only occur as part of terrace restoration under Alternative 3. 

No sediment would be produced from terrace restoration as modeled using Disturbed WEPP, but there 

would be a small amount, too small to measure, from the prescribed fire that would follow the terrace 

restoration. 

Twenty-three culverts would be removed in the Piquett Creek watershed, 10 in the East Piquett 

subwatershed and 13 in the Piquett subwatershed, creating about 0.04 ton (80 pounds) of sediment (Foltz et 

al. 2007). This sediment would be deposited immediately downstream of the crossings. In the long term, 

annual sediment transport to the streams would be reduced by 23.8 tons (Table 3.6-16). 

The minor amount of ECA created under this alternative would not change the overall percent ECA in the 

Piquett Creek subwatershed. This subwatershed, however, has a moderate risk that high water yields 

would cause channel changes in Piquett Creek. 

It is unlikely that the sediment deposited by the erosion event in 2009 would have an effect on the activities 

proposed by Alternative 3 for two reasons. First, the erosion event occurred upstream of proposed 

Subwatershed

Existing 

ECA

(acres)

(% ECA)

Additional 

ECA (acres)

(% ECA)

Sediment from Prescribed 

Fire (tons)

(Probability of Input) 

Number of culverts 

removed

(Long-term Sediment 

Reduction (tons/year))

East Piquett 1,829

(34) 

15

(35) 

0.5

(0-3%)

10 Removed, 7 Contribute

(-11.9) 

Piquett (excluding

East Piquett)

9,306

(61)

7

(61)

1.6

(0-3%)

13 Removed, 7 Contribute

(-11.9)

Piquett, including 

East Piquett

11,134

(54) 

22

(54) 

2.1

(0-3) 

23 Removed, 14 Contribute

(-23.8) 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-35 

activities and second, by the time any activities are implemented, sediment would have been transported 

downstream out of the planning area. 

In summary, Alternative 3 would not measurably increase sediment in Piquett Creek. The potential for 

sediment contributions from the Rombo Fire is moderate to high for the next two to three years depending 

upon weather and storm events and this could cause some channel configuration changes. The sediment 

contributions from Alternative 3 would be much less than those of the Rombo fire, and it would not be 

possible to distinguish them. Alternative 3 would not increase ECA beyond that associated with the fire. 

Alternative 3 would be consistent with Clean Water Act and Restoration Plan because channel conditions 

would be maintained during implementation and improve after the watershed restoration activities and 

vegetation recovery. There would be fewer sediment contribution points and less sediment would be 

delivered to Piquett Creek from the road system. 

The effects of Alternative 3 would be the same as under Alternative 2 regarding sediment contributions or 

ECA increases in the above subwatersheds, except Violet. In the Violet Creek subwatershed, only road 

decommissioning and storage would occur. Five culverts that contribute sediment would be removed, 

which would add about 0.4 ton (800 pounds) of sediment. However, long-term sediment contributions 

would be reduced by approximately 8.5 tons/year compared to 6.8 tons/year under Alternative 2 (Table 3.6-

17). 

Lower West Fork, HUC 0305

Terrace restoration would occur in the Pierce Creek subwatershed. No sediment would be produced from 

this activity because the flat slope of the terrace would limit sediment transport and if it did occur, it would 

be captured on the next lower terrace or the RHCA. 

In summary, Alternative 3 would not measurably increase sediment or water yields in any of the streams in 

the Lower West Fork HUC. Culvert removal would increase short-term sediment yields but long-term 

sediment contributions would be 1.7 tons lower under Alternative 3 than Alternative 2. 

Table 3.6- 17: Condition of HUC 0305, Lower West Fork, Following Treatment 

C. Cumulative Effects 

The watershed resources cumulative analysis area follows the watershed boundaries upstream of the West 

Fork River and East Fork confluence and below Painted Rocks Dam (Fig 3.6-1). The area of cumulative 

effects includes the West Fork drainage downstream of Painted Rocks Dam, and the confluence of the Nez 

Perce Fork downstream to the confluence with the East Fork of the Bitterroot River. The area above 

Painted Rocks Dam is excluded from the analysis because the dam regulates stream flow and effectively 

traps sediment from higher in the watershed. The lower West Fork River has lower peak flows and higher 

Subwatershed

Existing 

ECA

(acres)

(% ECA)

Additional ECA 

(acres)

(% ECA)

Sediment Contributions 

from Prescribed Fire 

(tons)

(Probability of Input)

Number of culverts 

removed

(Long-term Sediment 

Reduction (tons/year))

Pierce 120

(9)

40

(13)

11.1

0-27%y

3 Removed, 2 Contribute

(-3.4)

Lavene 352

(27)

14

(28)

6.6

0-23%

1 Removed, 1Contribute

(-1.7)

Troy 25

(5)

28

(11)

0.8

10-17%

1 Removed, 1Contribute

(-1.7)

Violet 507

(69)

0

(69)

Not applicable, no

prescribed fire proposed

5 Removed, 5 Contribute

(-8.5)

Lower West Fork 2078

(5)

155

(6)

1.0

10-23%

2 Removed, 2 Contribute

(-3.4)
Affected Environment and Environmental Consequences - Watershed

3.6-36 Lower West Fork Project Final EIS 

summer flows, and a lower sediment load below the dam than would occur in the natural hydrologic 

regime. 

Past, present, and foreseeable activities in the cumulative effects analysis area contribute sediment to the 

lower West Fork River and affect channel conditions in sensitive “C”stream types near West Fork Lodge 

below Christisen Creek and in the vicinity of Troy Creek. Most of the lower West Fork River is a very 

stable “B” stream type. 

The potential for transporting sediment to streams from log hauling, prescribed fire, or culvert removal and 

road decommissioning is generally up to five years from creation of the sediment source(s) or until 

vegetation regrows to protect the soil and hold it in place. Timber management effects on water yield can 

last up to 10 years depending on the management intensity and the time needed for vegetation to attain the 

density, size, and vigor to use the available soil moisture. 

Roads, timber management, fire, subdivision and riverfront development, Painted Rocks Dam 

management, livestock grazing, and climate change all occur in the analysis area and influence the 

hydrology of the lower West Fork watershed. 

Roads are the greatest source of sediment to streams within the analysis area, especially the roads that 

encroach along Pierce Creek and Frazier Draw. These roads have been in place for over 40 years. They 

have negatively affected the watershed resource by: 

Roads

Ø increasing sediment delivery in specific locations 

Ø permanently removing a good portion of the historic overstory vegetation and other vegetation 

that contributes to stable stream banks 

Ø reducing woody debris recruitment 

Ø straightening the stream channel, which causes higher velocities, and more bank erosion 

Ø separating the stream from its floodplain or making the floodplain more narrow 

Ø filling wetlands 

Ø altering stream hydraulics at road crossings 

Ø allowing people easy access, which increases vehicle impacts, illegal firewood cutting, garbage 

dumping, and clearing of dispersed campsites 

In recent years, many encroaching road segments have been upgraded by graveling and improving 

drainage. Although upgrades reduce sediment production from the road surfaces, they will not eliminate 

the negative effects of locating roads in the stream bottom. Road segments that are not relocated out of the 

stream bottoms will continue to cause chronic sedimentation. 

Most of the roads on National Forest are upland, side-slope roads that cross numerous small, headwater 

streams. They do not encroach on floodplains for long distances, but they contribute sediment at the 

crossings. The Restoration Plan identified these crossings as sediment sources in the Lower West Fork 

watershed. Sedimentation from the crossings is considerably less than that produced by the encroached 

road segments, because there is less road prism within sediment transport distance to streams. 

West Fork highway is relatively flat, has well vegetated ditches, and is a negligible sediment producer. 

West Fork highway has been in or near its present location for nearly a century. For many decades, it 

negatively affected channel conditions in much the same manner as described above for encroached forest 

roads. The major difference is it has been paved for more than 30 years so sediment production from the 

asphalt surfaces and ditches has decreased. Sediment contributions from the highway are mostly sidecast

from winter sanding in a few encroached spots. Highway maintenance has had little effect on the West

Fork River. Pebble counts near the West Fork Ranger Station and below Piquett Creek indicate that that 

substrate is similar to or coarser than reference streams. 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-37 

Private roads in the analysis area are located along the river corridor. They are mostly short driveways that 

connect homes and properties to the West Fork highway. They are located on various slopes, and although 

they may be relatively unstable and erode easily, they do not contribute significant quantities of sediment to 

the river or its tributaries. 

No permanent roads would be constructed in Alternatives 2 and 3 and the short segments of temporary road 

would be located at upland locations that would not cross RHCAs (except for the culvert crossing on the 

existing prism in Unit 34) or contribute sediment to the West Fork. The temporary roads would be 

decommissioned following their use. 

In summary, the portion of the West Fork River that flows through the Lower West Fork watershed is 

coarser than the TMDL sediment target and contains sediment levels that are similar to reference conditions

based on pebble counts. Although some of the small Lower West Fork tributaries contain elevated 

sediment levels, their combined discharges comprise only a small fraction of the total discharge of the 

River. The Lower West Fork River has been able to transport sediment from the tributaries without 

showing visible depositions. In addition, most of the tributaries on the west side of the river flow into 

wetlands formed by the highway. The wetlands filter the sediment before it is transported to the river. The

West Fork River does not form deltas or bars near the mouths of the small tributaries. Deltas or a bar at the 

mouths of the tributaries indicates sediment deposition in excess of what the river can carry. Consideration 

of all the incremental road sediment sources described above with the sediment inputs expected to enter the 

river from this project, the effect on stream channels would be undetectable. Based on pebble count 

monitoring, it is very unlikely that project sediment would combine with the other incremental sources to 

cause a visible or measurable change in water quality (PF-WAT-2). 

Twenty-four miles of 28 roads have been closed, seasonally or year-long, under the Nez Perce Travel 

Management Project (1997/1999). In 2006, NFSR 13431 in Piquett Creek was closed to full sized vehicles 

and culverts were removed. An unauthorized ATV trail was closed and revegetated. Under the Frazier 

Interface project, NFSR 363 and NFSR 5634, adjacent to Pierce Creek, were graveled and an undersized 

culvert on NFSR 74348 was removed and revegetated. These improvements reduced sediment sources and 

contributed to improving trends in Frazier Draw, Pierce Creek, and numerous other streams in the analysis 

area.

For all of the timber sales that have occurred in the West Fork drainage, the road construction, 

maintenance, and traffic associated with the sale contributed more sediment to streams than the timber 

harvest. Forest Service timber sales conducted between the early 1960s and the initiation of the Montana 

SMZ Law in 1993 caused more widespread, persistent negative effects on watershed resources because 

they required new road construction, were predominantly regeneration harvest, harvested, and skidded 

through riparian areas and the headwater tributaries, dozer piled slash, and used more intensive site 

preparation. These harvests are factors that have contributed to the fair to poor stream channel conditions 

in some streams of the Lower West Fork watershed. 

Timber Harvest 

Timber harvest in Violet Creek was completed in 1987. Violet Creek harvest increased ECA and resulted 

in localized water yield increases. ECA has recovered slightly in the last 20 years by the regeneration of 

clearcuts and growth of new forest. Violet Creek does not connect to or contribute surface water and 

sediment to the West Fork River. Proposed activities would follow INFISH standards and analysis 

indicates sediment or ECA increases would be small. The effects of the proposed treatments combined 

with past harvest effects would not be large enough to cause changes to the Violet Creek stream channel

(Table 3.6-15). 

Regeneration harvest has the largest effect on the watershed resource due to potential water and sediment 

yield increases. No regeneration harvest has occurred in the Lower West Fork area since 1992. The most 

recent regeneration harvest occurred in the Castle Creek watershed, a tributary to Piquett Creek. Sediment 
Affected Environment and Environmental Consequences - Watershed

3.6-38 Lower West Fork Project Final EIS 

sources from past sales have recovered because disturbed soils stabilize within 3-5 years (Elliot 2000). 

Timber harvests that occurred more than 30 years ago have not delivered sediment to streams for many 

years and have recovered hydrologically because they are stocked with young trees. INFISH monitoring 

indicates that buffers effectively prevent sediment delivery from harvest units to streams (2006 Forest Plan 

Monitoring Report, Item 22). 

The Frazier Interface Fuels Reduction Project is an ongoing project that recently finished thinning about 

450 acres in Pierce Creek and Frazier Draw, on the west side of the West Fork River. Prescribed fire has 

occurred and will be finished on most of this area in the next few years. Monitoring this project area found 

these activity-generated sediments did not enter RHCA buffers or streams (2006 Forest Plan Monitoring 

Report, Item 22, PF-FISH-7). It is unlikely that effects of the Frazier Interface Project would combine with 

the timber management and prescribed fire treatment effects of the Lower West Fork project to have a 

measurable cumulative effect on stream channels in the Lower West Fork analysis area. 

Timber thinning has occurred on private land at the mouth of Piquett Creek. The exact effects of this 

project are unknown but sediment transport to Piquett Creek is not apparent. There is a wide, low gradient, 

well-vegetated buffer between the harvested area and both the West Fork River and Piquett Creek. It is 

unlikely that sediment from this project entered these streams. 

Another recent private timber sale in the Pierce Creek watershed was completed in 2006. This project 

included riparian road construction along Pierce Creek. The road location has the potential to affect 

conditions in Pierce Creek more than the harvest because it was located within the RHCA. However, 

evidence of increased sediment in Pierce Creek was not found during 2005 monitoring conducted after the 

road construction (PF-WAT-2). Pierce Creek also flows into a wetland so sediment from the private land 

harvest would be deposited before it enters the West Fork River. The Lower West Fork project would not 

deliver measurable sediment into the West Fork River. 

Timber harvests have not caused noticeable sedimentation or changes to stream channel conditions since 

the Bitterroot NF applied INFISH standards to timber harvests after 1995. Timber harvest and skidding 

logs no longer occur in RHCAs. Monitoring has not revealed any sediment concerns from the log yarding 

or other activities associated with timber harvest. None of the sales that are more than three years old poses 

sediment risks in the future. Post-1995 timber sales have negligible effects on the watershed resource. 

Further, it is unlikely that the Lower West Fork project combined with private land harvests and past 

National Forest harvests in the watershed would cause measurable sediment delivery to the West Fork 

River.

In summary, Forest Service timber harvest since 1995 has not caused noticeable changes in the Lower West 

Fork watershed on watershed resources. Activities in the RHCAs have been restricted or prohibited, and 

the RHCA filtered sediment before it could enter the stream. 

The timber management activities proposed in Alternatives 2 or 3 would incorporate the following key 

mitigations: 

Ø All activities would comply with INFISH standards and guidelines

Ø No timber management would occur in RHCA buffers 

Ø All yarding would comply with Region 1 soil quality standards 

Ø No new permanent roads would be constructed 

Ø Temporary roads would be limited, and would be located on dry ridgelines, midslopes, or use 

existing road prisms. They would not cross or enter RHCAs. These roads would be 

recontoured and revegetated after use. 

Ø Tracked line machine skid trails would be limited, located on ridges, and would not enter 

RHCAs. No sediment would be transported from track line machine trails due to their location 

outside of RCHAs. 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-39 

Ø Roads would be stored or decommissioned in both Alternatives 2 and 3 to reduce sediment 

sources.

Ø Soil and Water Conservation Practices (BMPs) would be applied to all harvest and vegetation 

management activities. 

Because of these mitigations, the combination of Alternatives 2 or 3 and the effects from past timber sales 

would not likely have significant cumulative effects on the watershed resource. 

Several weed treatment analyses overlap the Lower West Fork analysis area and would need to be reviewed 

annually when planning activities related to this project. This includes 1998 Noxious Weed Environmental 

Assessment, 2003 Noxious Weed Treatment Project, possible treatments associated with the Frazier 

Interface Fuels Project, and the 2009 Selway Bitterroot Weeds FEIS. Herbicide use and application rates, 

as designed and mitigated in these analyses, are below levels that would affect fish or water quality. As 

long as herbicide treatment is within the maximum allowable area, water quality would be protected. 

However, the Noxious Weed Program Manager will need to ensure that application rates for all projects are 

considered when planning annual treatments and those applications do not exceed recommended levels

(PF-WAT-35, Watershed Cumulative Effects Worksheet, Fisheries Cumulative Effects Worksheet, and 

Fisheries Report). 

Herbicide Application

The Rombo Fire burned approximately 11,134 acres in the Piquett watershed at moderate and high 

intensity in 2007. Post-fire emergency sediment modeling predicted up to 8.6 tons of sediment/acre would 

be contributed to Piquett Creek. The sedimentation occurrence in July 2009 is an example of one source of 

the predicted sediment. This is much more sediment than would be contributed by all of the proposed 

activities in the Lower West Fork project. Any sediment contributed by Alternative 2 or 3 would not be 

measurable in Piquett Creek, nor would it be possible to separate the effect of activity sediment from that of 

the fire. 

Fire

In the West Fork River, some of the fire sediment would be stored in the river substrate, side channel bars, 

or flood plains, and the rest would be transported through the system. Monitoring of the East Fork after the 

fires in 2000 found that substrate composition fluctuated annually but substrate composition has been stable 

for the past 8 years (2006 Forest Plan Monitoring Report, Item 17). It is likely that similar sediment 

movement would occur in West Fork River but at a smaller scale.

The Rombo Fire created openings in the Piquett watershed that increased ECA to 61% in the portion of 

Piquett Creek that excludes East Piquett, or to 54% in the entire watershed. As a result, there is a moderate 

risk of some changes in water yields to both Piquett and East Piquett Creeks in either timing or quantity. 

The activities proposed in Alternative 2 or 3 are small compared to the fire effects; Alternative 2 increases 

ECA by one percent in East Piquett Creek but there is no change in ECA in main Piquett Creek. This 

minor increase is not likely to increase the risk of channel adjustments to a measurable degree when 

combined with the risk created by the fire.

Monitoring of dozer line restoration following the fires in 2000 indicates that dozer lines restored after the 

Rombo fire will recover within 2-3 years (2005 Forest Plan Monitoring Report, Item 22). 

Prescribed fire activities in the analysis area have added little sediment to streams (2006 Forest Plan 

Monitoring Report, Item 22; PF-FISH-7). These activities are designed to be predominantly low intensity 

and severity, and typically do not consume the entire duff in the units. Maintaining a duff layer preserves 

the infiltration capacity of the soil, and effectively limits overland flow and sediment transport to streams 

(USDI Fish and Wildlife Service 2001, pg 6). For these reasons, the combined effects of Alternatives 2 or 

3 with fire would not be measurable. 
Affected Environment and Environmental Consequences - Watershed

3.6-40 Lower West Fork Project Final EIS 

Low-density subdivisions have spread across most of the private West Fork River corridor between 

Trapper Creek and the confluence with the Nez Perce Fork. These areas are not large sediment producers, 

but they do contribute to reduced shade, increased nutrient loads, reduced woody debris recruitment from 

stream bank clearing, reduced bank stability, and substandard crossings on access roads. Alternatives 2 or 

3 would not contribute to increased nutrients or alteration of woody debris recruitment because the RHCAs 

would not be thinned and sediment would be buffered by the RHCAs. Alternative 2 or 3 would not add to 

effects on the West Fork River from subdivisions and riverfront development. 

Subdivision and Riverfront Development

Painted Rocks Dam is located approximately ten miles upstream of the project area. Dam operations 

moderate stream flow in the lower West Fork River by decreasing peak flow and increasing summer low 

flows. Dam operations also reduce sediment transported from upstream areas, and alter temperature 

patterns in the late summer. Alternative 2 or 3 combined with the dam management would not change or 

add to the effects of dam management on the West Fork River. 

Painted Rocks Dam Management 

These projects are grouped together because they produce localized short-term sediment increases during 

implementation, but create long-term sediment reductions and benefits to the hydrologic and aquatic 

systems. One to five years following implementation, when the disturbed soils have revegetated, these 

projects pay dividends in the form of long-term sediment reductions from the road network, and 

incremental improvements in overall watershed health. 

Road Decommissioning, BMP Upgrades, and Culvert Replacements

In 1997 and 1998, the Nez Perce Watershed Improvement Project was implemented in the area between 

Pierce and Ward Creeks. The season of travel was changed on some roads, other roads were stored, and 

sediment sources were treated (PF-WAT-14). Twenty-four miles of road in the Lower West Fork analysis 

area were included in this project. Field inventories indicate that the treated roads no longer contribute 

sediment to streams. The road treatments in Alternatives 2 or 3 would have similar effects and add to the 

overall decrease in stream sediment load. 

There is one grazing allotment in the analysis area, Piquett Creek, which has not been grazed on a regular 

basis since 1995. It was grazed in the summer in 2001 to provide a season of rest on an allotment that

burned in 2000. The main grazing pastures are located in the higher elevation grasslands, not in RHCAs. 

Therefore, the allotment has very limited effects on Piquett Creek or the West Fork River. There would be 

no cumulative effects relative to sediment or water yield from this allotment and Alternatives 2 or 3. 

Livestock Grazing 

This allotment is being considered for short periods of use as needed to rest other allotments. When used 

only for short time periods, there would be low risk of negative grazing effects because vegetation would 

have time to recover between grazing periods. Adequate vegetation is available to allow short duration 

grazing and limit shrub browsing, which would maintain bank stability. 

Private Lands: A limited amount of riparian grazing occurs on private lands throughout the analysis area. 

Riparian area grazing causes bank trampling, increases channel erosion and widening, and reduces shade. 

The riparian grazing in the Lower West Fork analysis area is spaced across the landscape and its effects are 

separate and isolated from effects on other private land parcels. None of the grazing effects would combine 

with effects of Alternatives 2 or 3 and cause negative effects on the watershed resource. Collectively, the 

total sediment these grazed areas contribute to channels in the Lower West Fork analysis area is small and

indistinguishable from the natural background sediment levels of the river. When combined with the small 

amount of potential sediment that could be added to the West Fork River in Alternatives 2 or 3, the 

cumulative effect on streams would be unmeasurable. 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-41 

Water resource effects depend upon both climatic and non-climatic factors such as forest canopy growth, 

population changes, and human uses of water. Current research (Running, 2006, Mote et al, 2005) 

observes that snowmelt and spring runoff occur earlier than in the past and as a result there are more dry 

months. They estimate 2-5 degrees Celsius warming in the west, while average precipitation is not 

expected to change. The expected result is that fire seasons will be longer and higher elevation forests will 

be drier and more vulnerable to fire (Running 2006). 

Climate Change 

The effect of this project on global warming is not measurable. Although a thinned forest may cause higher 

ground surface temperatures from solar energy reaching up to 25% more of the forest floor, it will not

contribute to higher temperatures globally. Thinning would increase soil moisture by removing some of 

the trees but the remaining stand would utilize the additional moisture. ECA increases would not be large 

enough to cause increased runoff or changes in the stream channels (refer to the Direct and Indirect Effects 

section), and runoff would be indistinguishable from the current level. 

The following past, current, and foreseeable activities have been discounted from the cumulative effects 

analysis because their incremental effects have negligible impacts on streams. These activities contribute 

undetectable amounts of sediment or water to streams in the project area, have neutral effects on riparian 

areas, are located too far from the project area to have measurable effects on streams, are mitigated to the 

extent that effects are unmeasurable, or no longer have the potential to generate cumulative effects because 

they occurred too long ago. 

Other Activities with Negligible Effects

Ø Tree planting activities

Ø Manual thinning in tree plantations

Ø Fertilization of tree plantations 

Ø Manual thinning fuels reduction 

projects 

Ø fires in 2000 (BAER rehabilitation 

activities) 

Ø Fish stocking 

Ø Outfitter and guide activities 

Ø Hunting 

Ø Developed campsites (construction, 

use, & maintenance)

Ø Dispersed campsites (construction, use, 

& maintenance)

Ø OHVs

Ø Forest Service trails (construction, use, 

& maintenance)

Ø Forest Service facilities (use & 

maintenance) 

Ø Christmas tree cutting

Ø Mushroom and special products harvest 

Ø Ditches and irrigation withdrawals

3.6.6 CONSISTENCY WITH THE BITTERROOT FOREST PLAN AND OTHER 

REGULATORY DIRECTION

A. Bitterroot National Forest Plan 

This project is consistent with the Bitterroot National Forest Plan (USDA Forest Service 1987) goals, 

objectives, and resource standards in the following ways:

Objective:

The Forest-wide goal for soil and water resources is to:

Ø Maintain soil productivity, water quality, and water quantity (Forest Plan pg. II-3). 

How Addressed: 

Hydrology, Soils, and Fisheries specialists minimized impacts to watershed values during the 

Interdisciplinary Team (ID Team) planning process. They instituted standard environmental protections 

through the planning process, harvest unit design, and road management. These protections included 
Affected Environment and Environmental Consequences - Watershed

3.6-42 Lower West Fork Project Final EIS 

determinations of stream health, watershed sensitivity, and cumulative impacts. Design restrictions and 

improvements were incorporated in the project such as soil restoration, road maintenance, road storage 

or decommissioning, and limits on forest canopy reduction. 

Objective:

Forest–wide Management Objectives state how resources will be managed under the Forest Plan:

Ø Manage riparian areas to prevent adverse effects on channel stability and fish habitat (Forest 

Plan pg. II- 6). 

How Addressed: 

During the planning process, RHCA buffers are established around streams to promote riparian 

objectives. Unless an activity helps attain fishery or riparian objectives, the RHCA is generally a zone 

of no active management. The ID Team analyzed the project effects on watershed functions (i.e. water 

yield increases from timber harvest) and used the results to eliminate or limit negative impacts.

Forest-wide Management Resource Standards:

Objective:

Ø Utilize equivalent road area or similar concept to evaluate cumulative effects of projects 

involving significant vegetation removal, prior to including them on implementation schedules 

(Forest Plan pg. II-23) 

How Addressed: 

The ID Team used Equivalent clearcut area (ECA) to evaluate whether vegetation removal exceeded 

thresholds in the Lower West Fork project area. ECA in Violet Creek was well over the 20-25% 

threshold where the probability of changing channel configurations increases. Stream surveys, 

however, indicate the channel is stable and functioning properly. The proposed activities would 

increase the ECA less than 1%. This slight increase would not translate into measurable changes in 

channel condition. 

Prescribed fire would increase ECA to 31.6% in Lavene Creek. Though this level exceeds the 25% 

threshold, the prescribed fire is designed to imitate the historically more common open forest. 

Objective:

Ø Maintain the percentage of “hydrologically unrecovered” area permitted in a landscape within 

the guidelines of Table II-5 of the Forest Plan (pg. II-24). This applies to regeneration harvests 

only. 

How Addressed: 

No regeneration harvests have been proposed in the Lower West Fork project. Hydrologic effects of the 

partial cuts were estimated using an ECA model that pro-rate past and proposed harvest on percentage 

basal area removed and duration since treatment. All ECAs fall below Forest Plan recommendations in 

Table II-5 (Forest Plan pg II-24) except in Violet Creek and Lavene Creek watersheds. The slight 

changes resulting from treatments as described in the objective above would cause no measurable 

increases in streamflow. Therefore, treatments follow Forest Plan guidelines. 

Objective:

Ø As part of project planning, site-specific water quality effects will be evaluated and control 

measures designed to ensure that the project would meet Forest water quality goals; projects that 

will not meet State water quality standards will be redesigned, rescheduled, or dropped (Forest 

Plan pg. II-24). 

How Addressed: 

Hydrology, Soils, and Fisheries specialists worked with the ID Team to minimize impacts to watershed 

values. The ID Team instituted standard environmental protections through the planning process, 

harvest unit design, and road management. These included determination of stream health, watershed 

sensitivity, and cumulative impacts. Where necessary, further restrictions and improvements were 

included (e.g. soil restoration, stream crossing removal, road storage or decommissioning). 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-43 

Objective:

Ø Soil and water conservation practices will be a part of project design and implementation to 

ensure soil and water resource protection (Forest Plan pg. II-25). 

How Addressed: 

Soil and water conservation practices were included in the project design: 

o RHCA buffers have been built into harvest units to reduce effects to riparian areas

o Appropriate yarding methods have been developed to minimize soil impacts and 

sedimentation 

o BMPs are included in all timber sale contracts

o Special mitigations and watershed improvements have been proposed to minimize effects 

(e.g. straw bale sediment trap installation at sediment producing crossings or locations). 

o Alternative 2 decommissions about 9.6 miles of unneeded roads and stores 18.7 miles of 

roads not needed in the near term.

o Alternative 3 decommissions about 26.8 miles of unneeded roads and stores 18.1 miles of 

roads not needed in the near term. 

Objective:

Ø Actively reduce sediment from existing roads. Sediment reduction measures include:

o Cross-drains into vegetative filter strips away from streams

o Grass seed, fertilized, mulch and netting on cuts and fills 

o Slash filter windrows or straw bales at toe of fill in contributing areas

o Gravel ditches and road surfaces (Forest Plan pg. II-25) 

How Addressed: 

This objective was addressed by:

o Proposing replacement of seven fish barrier culverts with fish-passable structures.

o Removing two fish barrier culverts and restoring the natural channel shape.

o Eliminating a “double crossing” on NFSR 5630 in Lavene.

o Decommissioning and storing roads as described in objective “Soil and water conservation 

practices will be a part of project design...” above. 

Management Areas 2 and 3a have another Management Standard that pertains to water resources:

Objective:

Ø Utilize watershed rehabilitation projects such as stabilizing road cut or fill slope slumps to repair 

problems (Forest Plan pg. III-6, 12, 18, 33, 59) . 

How Addressed: 

See discussion above for “Actively reduce sediment from existing roads.”

B. Montana State Regulation 

How Addressed: 

Montana Streamside Management Zone Act 

The law prohibits seven forest practices in SMZs:

1. Broadcast burning; (unless approved by the department under site-specific alteration practices)

2. Operation of wheeled or tracked vehicles except on established roads

3. The forest practice of clearcutting (unless approved by the department under site-specific alteration 

practices)

4. Construction of roads except when necessary to cross a stream or wetland

5. Handling, storing, applying, or disposing of hazardous or toxic materials in a manner that pollutes 

streams, lakes, or wetlands, or that may cause damage or injury to humans, land, animals, or plants 

6. Side-casting of road material into a stream, wetland, or watercourse

7. Depositing slash in streams or other water bodies 
Affected Environment and Environmental Consequences - Watershed

3.6-44 Lower West Fork Project Final EIS 

The Forest Service reviewed the proposed activities for compliance with the SMZ Act. SMZ width is 

either 50' on streams where side slopes are equal or less than 35% and 100' on streams with side slopes over 

35%. In Class 1 streams and lakes at least 50% of the trees >8" dbh on each side of the stream or 10 trees 

per 100' segment, must be retained, whichever is greater. Leave tree species and sizes should represent the 

original stand. 

The Lower West Fork project proposed harvest and prescribed burn projects meet or exceed these criteria. 

No waivers of this law will be requested. 

Best management practices (BMPs) are the foundation of water quality standards for the State of Montana. 

Specific BMPs were developed to reduce non-point source sediment related to silvicultural activities. The 

Forest Service agreed to follow BMPs in a Memorandum of Understanding with the State of Montana. 

Administrative Rules of Montana (ARM) 16.20.603 

How Addressed: 

This proposal directly applies many BMPs as general mitigations. Timber sale contract administrators 

routinely monitor BMP implementation and effectiveness. BMPs are also monitored during annual 

Forest Plan and other program reviews. A monitoring plan for this project is in PF-WAT-7. 

This regulation details water quality standards for the State of Montana. The Forest Service has primary 

responsibility to maintain these standards on lands under their jurisdiction in the State of Montana. 

ARM 17.30 Sub-chapter 6 

How Addressed: 

The Forest Service analyzed the potential effects of all activities on water quality, and considered them 

in context of existing conditions, stream type, and designated beneficial uses. They also reviewed the 

effects for compliance with existing regulations (i.e. MT SMZ law, INFISH Forest Plan Amendment, 

Road & Harvest BMPs, Forest Plan Standards & Guidelines, and Clean Water Act). The Forest Service 

specified protective measures that would limit or prevent detrimental effects. 

C. Clean Water Act

The Clean Water Act (CWA) and its various amendments are the foundation of water resource protection 

in the United States, and provide guidance at all levels of management. Pertinent components of the CWA 

include: 

Ø Section 208 of the 1972 amendments to the Federal Water Pollution Control Act (Public Law 

92-500) specifically mandates identification and control of nonpoint-source pollution resulting 

from silvicultural activities. 

How Addressed: 

Section 208 is addressed by including BMPs into the planning, design, and implementation of the 

project. Watershed, soils, and fisheries specialists on the ID Team incorporate non-point source 

prevention measures into silvicultural and other project activities. Planning BMPs include the location 

of harvest units and temporary roads to minimize or eliminate sediment production. Design BMPs 

include selecting yarding methods with the lowest impact, and designating season of operation, landing 

locations, and skid trail layouts. Lastly, the timber sale contract incorporates a large number of BMPs, 

which timber sale administrators and resource specialists monitor to ensure effective implementation. 

Ø Clean Water Act, Section 303 (d) directs states to list water quality impaired streams (WQLS) 

and develop total daily maximum loads to control the non-point source pollutant causing loss of 

beneficial uses. 

Ø Section 319 directs states to develop programs to control non-point source pollution, and 

includes federal funding of assessment, planning, and implementation phases. 

Ø Section 404 controls the dredge and fill of material in waterbodies of the U.S 
Affected Environment and Environmental Consequences - Watershed

Lower West Fork Project Final EIS 3.6-45 

How Addressed: 

The analysis reviewed the 2006 Montana 303d list of Water Quality Impaired Streams 

(http://www.deq.state.mt.us/wqinfo/index.asp) and considered recommendations in the Restoration Plan 

in the development of alternatives. In 2005, Bitterroot NF personnel surveyed channel substrate 

composition at multiple sites in the lower West Fork River and incorporated the findings in the 

alternative designs and effects analysis. 

S(319) consistency requires the entity proposing an activity with potential watershed effects to research 

whether any federally or state-funded watershed improvement projects would be affected. There are 

currently no S(319) cost-sharing agreements authorized within the project area watersheds (Mark Kelly, 

email 4/24/2008). 

S(404) involves regulations controlling the dredge and fill of wetlands; typically, this applies to roads 

where they cross streams, ponds, or wetlands. Silvicultural roads generally receive an exemption from 

specific permitting through a nationwide permit. Culvert replacement for fisheries improvement or 

culvert removal for watershed improvement may fall under this nationwide permit or may require 404 

permitting. Any activities developed from this analysis will be properly permitted under the CWA and 

MTDEQ regulations before implementation. 

D. Executive Order No. 11988 and 11990, Floodplain and Wetland Protection 

Executive Order No. 11988 direction for management within floodplains and Executive Order No. 119900 

provides direction for wetland protection. No activities are proposed in floodplains and buffers from 100-

300 feet are required by INFISH. No timber harvest would occur and no equipment would operate in 

wetlands. Prescribed fire would be allowed to back into wetlands to facilitate regeneration of wetland 

vegetation. Prescribed fire would not degrade wetlands but enhance function and improve diversity. 

All legal direction pertinent to this project and protection of water resources has been reviewed for 

consistency. In the opinion of the water resources specialist, the Lower West Fork project is consistent 

with all Forest Plan, State, and Federal direction guiding land management activities. 

Summary – Consistency with Legal and Policy Direction
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-1

3.7 FISHERIES 

3.7.1 INTRODUCTION 

The Lower West Fork analysis area is home to seven native fish species and three non-native fish species. 

The native species include bull trout (Salvelinus confluentus), westslope cutthroat trout (Oncorhynchus 

clarki lewisi), mountain whitefish (Prosopium williamsoni), longnose sucker (Catostomus catostomus), 

largescale sucker (Catostomus macrocheilus), and slimy sculpin (Cottus cognatus). The non-native species 

include rainbow trout (Oncorhynchus mykiss), brook trout (Salvelinus fontinalis), and brown trout (Salmo 

trutta). This analysis focuses on impacts to bull trout and westslope cutthroat trout. The information 

presented in this chapter is a summary of the existing condition. If the reader desires more detailed 

information, they should consult the Fisheries Specialist Report in the project file (PF-FISH-001). 

3.7.2 REGULATORY FRAMEWORK 

The primary document that governs the fisheries resource is the Bitterroot National Forest Plan (Forest 

Plan) (USDA Forest Service 1987) as amended by the 1995 Inland Native Fish Strategy (INFISH) (USDA 

Forest Service 1995). Other supplementary documents include: 

Ø The Endangered Species Act

Ø The Bull Trout Biological Opinion (USDI Fish and Wildlife Service 1998) 

Ø The Bull Trout Recovery Plan (USDI Fish and Wildlife Service 2002)

Ø The Montana Streamside Management Zone Law (Montana DNRC 1994)

Ø The Westslope Cutthroat Trout Conservation Agreement (Montana DFWP 1999)

Ø Water Quality Restoration Plan and Total Maximum Daily Loads for the Bitterroot Headwaters 

Planning Area

The bull trout is listed as a Threatened species under the Endangered Species Act. The portions of the 

West Fork Bitterroot River that flow through private lands are designated as critical habitat (USDI Fish and 

Wildlife Service 2005). Critical habitat has not been designated on the Bitterroot National Forest

(Bitterroot NF). The Endangered Species Act requires preparation of a Biological Assessment to disclose 

the direct, indirect, and cumulative effects of the 

(Restoration Plan) (Montana DEQ 2005)

selected alternative

The westslope cutthroat trout is currently designated as a Sensitive species on the Bitterroot NF. A 

Biological Evaluation has been prepared for westslope cutthroat trout (FSM 2672.4), and incorporated into 

this document as directed by USFS Region 1 letter 2670/1950 (August 17, 1995). The Forest Plan 

designates the westslope cutthroat trout as the management indicator species for assessing the impacts of 

forest management on the fishery (USDA Forest Service 1987: pg. II-20). 

on bull trout and bull trout critical 

habitat. Prior to the release of the FEIS, the bull trout Biological Assessment will be written and a copy 

mailed to the U.S. Fish and Wildlife Service for their concurrence or opinion. At that time, a copy will also 

be placed in the project file (PF-FISH-002). When a concurrence letter or Biological Opinion is received 

from the U.S. Fish and Wildlife Service, it will be placed in the project file (PF-FISH-003). 

3.7.3 AREA OF ANALYSIS

The fisheries analysis focuses on the 16 streams that support fish in the Lower West Fork analysis area:

ØWest Fork Bitterroot River below Painted Rocks Dam

ØPierce Creek

ØBaker Creek (north and south channels)

ØLloyd Creek

ØChristisen Creek

ØLavene Creek

ØBoulder Creek

ØWard Creek

Ø Piquett Creek

Ø Piquett Creek, unnamed tributary 4.2

Ø Piquett Creek, unnamed tributary 6.2

Ø East Piquett Creek

Ø East Piquett Creek, unnamed tributary 2.0

Ø Britts Creek
Affected Environment and Environmental Consequences - Fisheries

3.7-2 Lower West Fork Project Final EIS 

Ø Castle Creek Ø Notch Creek

The analysis area also includes several streams that do not contain fish, but may contribute sediment and 

water to fish habitat in the West Fork River during high flows. These streams include Frazier Draw, Troy 

Creek, Violet Creek, Pine Creek, Swamp Creek, Wheeler Creek, Applebury Creek, Steep Gulch, and 

several unnamed intermittent and perennial streams on both sides of the West Fork River between Trapper 

Creek and the Nez Perce Fork. These non-fish bearing streams provide seasonal habitat for other aquatic 

species such as amphibians and invertebrates. 

3.7.4 ANALYSIS METHODS 

Healthy bull trout and westslope cutthroat trout populations require clean substrates, cold water, complex

hiding cover (i.e. pools and woody debris), and populations that are connected

Ø Sedimentation (i.e. clean)

to each other (Rieman and 

McIntyre 1993). Collectively, these key habitat characteristics have been coined “the four C’s” (Montana 

Bull Trout Restoration Team 2000). For each alternative in this project, we analyzed potential effects to 

the fishery by using five evaluation criteria that closely correspond to “the four C’s.” These criteria are: 

Ø Water temperatures (i.e. cold)

Ø Water chemistry (i.e. clean)

Ø Woody debris recruitment (i.e. complex)

Ø Migration barriers (i.e. connected)

The data presented in this chapter was collected during the 2002-08 field seasons. The data collection 

methods and surveys are listed in detail in the Fisheries Specialist Report (PF-FISH-001). 

3.7.5 EXISTING CONDITION 

A. Fish Populations

Bull trout are present in four streams in the Lower West Fork analysis area (Fig. 3.7-1): 

Bull Trout

Ø The West Fork Bitterroot River (West Fork River) (rare)

Ø Boulder Creek (common)

Ø Piquett Creek (rare-to-uncommon)

Ø Castle Creek (rare)

Bull trout may still occupy close to 100% of their historic distribution in the Lower West Fork analysis area

but numbers are well below historic levels, and much of the current range overlaps that of non-native 

competitors (USDA Forest Service 2000a: pg. 49). 

The bull trout in the West Fork River are fluvial (migratory) fish. Both adults and juveniles are present in 

the West Fork River, but at low densities. In 2000, biologists estimated that the 23 miles of the West Fork 

River below Painted Rocks Dam contained less than 50 adult bull trout (USDA Forest Service 2000a: pgs.

49-50). Montana Fish, Wildlife, and Parks biologists typically capture 2-3 bull trout (most are less than 12 

inches long) per mile of river during their electroshock surveys. The adults live in the river for most of the 

year, and spawn in the tributaries in September and October. The West Fork River, below Painted Rocks 

Dam, primarily functions as a migratory corridor for adult bull trout, but also provides adult fish 

overwintering habitat and rearing habitat for juvenile fish. 

Boulder Creek contains about 5.7 miles of excellent bull trout spawning and rearing habitat. Bull trout are 

common in Boulder Creek, from the mouth to the base of Boulder Falls. We estimate that more than 500 

adult bull trout occupy Boulder Creek and most, if not all, are believed to be resident fish (USDA Forest 

Service 2000a: pgs. 49-50). 
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-3

Piquett Creek contains about six miles of bull trout spawning and rearing habitat. Bull trout are uncommon 

in the lower half of Piquett Creek, and more numerous in the upper half of Piquett Creek, though still 

uncommon, upstream of the Piquett trailhead. We estimate between 50 and 500 adult bull trout occupy 

Figure 3.7-1: Fish Distribution and Abundance in the Lower West Fork Analysis Area
Affected Environment and Environmental Consequences - Fisheries

3.7-4 Lower West Fork Project Final EIS 

Piquett Creek and most are resident fish (USDA Forest Service 2000a: pgs. 49-50). A few juvenile (2-4 

inches in length) bull trout are present in the lower half mile of Castle Creek near the Piquett Creek 

confluence.

Bull trout have not been found in any of the other fish-bearing streams in the Lower West Fork analysis 

area. Those streams may be too small to provide suitable bull trout spawning and rearing habitat for any 

appreciable distance upstream from their junctions with the West Fork River or Piquett Creek. 

Westslope cutthroat trout are common in all of the fish-bearing streams in the Lower West Fork analysis 

area, and are believed to occupy close to 100% of their historic habitat. The westslope cutthroat trout in the 

West Fork River are fluvial fish. Both adults and juveniles are present in the river. The juveniles are 

typically less than 10 inches in length, while adults range between 10 and 21 inches in length, with many 

adults greater than 14 inches. The catch-and-release regulations that have been in place in the West Fork 

River since the 1990s, along with increased voluntary use of catch-and-release by all anglers, has increased 

the number of large cutthroat trout in the lower West Fork River. Boulder and Piquett creeks are estimated 

to contain 5,000 to 15,000 westslope cutthroat trout, with most of those being resident fish. Most of the 

westslope cutthroat trout are small (2-6 inches) resident fish in the small tributaries, and populations in each 

tributary number between the hundreds to low thousands. Genetic testing of westslope cutthroat trout 

purity has been limited in the Lower West Fork analysis area, but in general, the results suggest that the 

westslope cutthroat trout population in the West Fork River consists of a mix of pure and hybridized 

(westslope X rainbow) fish, while the populations in the tributaries are genetically pure. 

Westslope Cutthroat Trout

The five native, non-trout species that are present in the Lower West Fork analysis area are generally 

restricted to the West Fork River. Mountain whitefish are abundant, and longnose dace and the two sucker 

species are common. Slimy sculpin are common in the West Fork River, and may occur in the lower ends 

of Boulder and Piquett creeks. None of the native, non-trout species are listed or designated as Sensitive. 

Native, Non-Trout Species

Three non-native fish species (brook trout, brown trout, and rainbow trout) are locally common in portions 

of the Lower West Fork analysis area. Brown trout and rainbow trout are generally confined to the West 

Fork River, while brook trout are common in the lower halves of Piquett and East Piquett creeks, and 

uncommon in the lower ends of Ward and Baker creeks. Over the years, an incidental rainbow trout or 

brown trout has been found in the lower ends of Piquett, East Piquett, and Castle creeks, but never in large 

numbers (i.e. usually one or two individuals). Rainbow and brown trout have largely replaced bull trout as 

the dominant predatory salmonids in the West Fork River below the dam. They pose at least a moderate 

threat to the persistence of bull trout and westslope cutthroat trout in the River (Rieman et al. 1993). The 

presence of rainbow and brown trout in the West Fork River below the dam is a major obstacle to the 

recovery of native bull trout and westslope cutthroat trout populations. Even if all of the habitat on the 

Bitterroot NF could be restored to its pre-settlement condition, the presence of large numbers of rainbow 

and brown trout in the rivers is likely to suppress or negate bull trout recovery (USDA Forest Service

2000a: pg. 52). 

Introduced Species

The 2007 Rombo fire burned about 40% of the fish habitat in the Piquett Creek watershed. The percent of 

burned fish habitat and the predominant fire severity in Piquett Creek and its fish-bearing tributaries are 

displayed in Table 3.7-1. With the exception of Britts and Notch creeks, the fire in the riparian areas 

burned in a patchy pattern, the predominant burn severity was low to moderate. Piquett Creek, the arterial 

stream in the watershed, had about 1.8 miles (26%) of its fish-bearing riparian areas burned. The burn 

severity along Piquett Creek was mostly low, with discontinuous patches of moderate severity. 

Rombo Fire Effects on Fish Populations
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-5

Table 3.7-1: Percent of Fish Habitat Burned and Fire Severity on 

Fish-Bearing Streams in the Piquett Creek Watershed

We did not observe dead, injured, or sickly bull trout and westslope cutthroat trout in any of the streams 

during or after the fire (USDA Forest Service 2007). Based on the patchy burn pattern of the fire in the 

fish-bearing riparian areas, and its generally low severity, it is unlikely that many fish were killed during 

the fire (USDA Forest Service 2002: pgs. 90-92; USDA Forest Service 2003: pgs. 92-98; USDA Forest 

Service 2004a: pgs. 112-116; USDA Forest Service 2005: pgs. 86-92; Sestrich 2005). If a fish kill 

occurred, the most likely stream would have been Britts Creek, a small westslope cutthroat trout tributary 

that was the most severely burned. 

The fish populations in Piquett Creek and East Piquett Creek were monitored in August 2008 to discern 

post-fire changes. In Piquett Creek, pre- and post-fire fish population numbers and species assemblages 

were similar (PF-FISH-001). In East Piquett Creek, post-fire numbers of all fish species were lower than 

those observed in 2006 and 2007 (PF-FISH-001). It is unclear if the decline was fire-related. The 

monitoring reach was unburned (as is most of the suitable fish habitat in East Piquett Creek); however, very 

high peak flows in June 2008 caused significant channel changes and bedload movement, which may have 

been the cause of the lower fish numbers we observed. 

An intense thunderstorm in the Piquett Creek drainage on the evening of July 26, 2009 that lasted through 

most of the day on July 27th caused turbid streamflow in Piquett Creek and the West Fork Bitterroot River 

below Piquett Creek. The source of the turbidity was accelerated runoff from severely burned soils (from 

the Rombo Fire) in the roadless headwaters of Piquett Creek. A similar turbid event occurred concurrently 

in Warm Springs Creek and the East Fork Bitterroot River. No debris flows or stream channel blow-outs 

occurred in the roaded and managed portion of the Piquett Creek drainage downstream of Castle Creek. 

Fire aircraft conducted a cursory search for debris flows in the roadless headwaters of the Piquett Creek 

drainage a couple of days following the July 26th event, but none were found. 

The turbid flows caused a moderate amount of sediment to be deposited in the low velocity sections of

Piquett Creek (e.g. the bottoms of pools, the margins of riffles, and downstream of flow obstructions). It 

also left a thin layer of silty sediment along the bottoms of pools and margins of riffles in the West Fork 

Bitterroot River below Piquett Creek. Based on our experiences following the 2001 mudslides, we expect 

the deposition to persist until the spring of 2010 when high flows will flush and rout the sediment further 

downstream. Dead, injured, or sickly fish were not found or reported following the July 26th runoff event. 

Based on fish population monitoring conducted in the East Fork Bitterroot River in 2001 following several 

days of extremely turbid flows (USDA Forest Service 2001a: pg. 3-277), and the absence of fish kill 

reports from anglers following the July 26th event, it does not appear that a fish kill occurred. The sediment 

deposition caused by the event will temporarily reduce aquatic insect production and stream bottom hiding 

cover for juvenile trout over the next 10 months or so until peak flows occur in spring 2010. By summer 

2010, aquatic insect production and juvenile hiding cover are expected to approximate pre-event 

conditions. 

Tributary Area Burned (%) Fire Severity

Piquett 26 low

Castle 78 low

Britts 100 moderate/high

Notch 100 moderate

East Piquett 20 low

East Piquett tributary 2.0 30 low

Piquett tributary 6.2 90 low
Affected Environment and Environmental Consequences - Fisheries

3.7-6 Lower West Fork Project Final EIS 

B. Fish Habitat

Overall, fish habitat is in good condition in the Lower West Fork analysis area, but below its natural 

potential in most of the streams. In the West Fork River, the main habitat impairments are the presence of 

Painted Rocks Dam and the West Fork Highway. Painted Rocks Dam creates a permanent fish barrier and 

water releases from the dam alter the discharge, wetted perimeter, and temperature in the lower West Fork 

River. The West Fork Highway encroaches on the lower West Fork River, reducing stream shade and 

woody debris, and disconnects tributaries from the River.

The main habitat impairments in the tributaries are culvert barriers and encroachment of National Forest 

roads (PF-FISH-001). In all streams, habitat conditions on private land are much worse than those on the 

Forest. The impairments to fish habitat are listed below. 

Ø Reductions in woody debris recruitment and shade caused by riverfront development and the 

encroachment of the West Fork Highway. In a few spots, the highway has reduced meander length

West Fork Bitterroot River between Conner and Painted Rocks Dam

Ø Alterations in discharge and temperature from the operation of Painted Rocks Dam 

Ø Reduced pool quality due to a shortage of woody hiding cover

Pierce Creek 

Ø Large woody debris is well below its natural potential due to road encroachment

Ø Summer water temperatures are warmer than reference conditions

Ø The encroachment of National Forest System Road (NFSR) 363 increases storm runoff and reduces 

woody debris recruitment, shade, and overall riparian function

Ø High road density in the watershed (4.9 miles/square mile), with six sediment contributing 

crossings

Ø Poor habitat conditions on private land due to riparian road construction, dewatering and 

channelization. As a result of these impacts, Pierce Creek no longer maintains its historic 

hydrologic connection to the West Fork River

Ø Five culverts internally fragment the westslope cutthroat trout population and block fish passage to 

the West Fork River

Ø Poor habitat on private land due to dewatering, channelization, and development

Baker Creek 

Ø Six culverts internally fragment the westslope cutthroat trout population and block fish passage to 

the West Fork River

Ø Poor habitat on private land due to dewatering, channelization, and development

Lloyd Creek 

Ø The highway culvert is a barrier that blocks fish passage to the West Fork River

Ø Poor habitat on private land due to dewatering, channelization, and development

Christisen Creek 

Ø Five culverts (on private land and the highway) block fish passage to the West Fork River

Ø Summer water temperatures are warmer than reference conditions

Lavene Creek 

Ø The location of NFSR 5630 in the (Riparian Habitat Conservation Area (RHCA) along the lower 

0.4 of a mile of stream reduces woody debris recruitment and shade

Ø High road density in the watershed (4.0 miles/square mile), with six sediment contributing 

crossings
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-7

Ø Four culverts internally fragment the westslope cutthroat trout population and block fish passage to 

the West Fork River

Ø Home construction in the Boulder Creek riparian area on private land

Boulder Creek 

Ø The culvert on the West Fork Highway is at least a partial barrier that blocks/impedes fish passage 

to the West Fork River

Ø The lower half mile of Ward Creek is dewatered during the heat of the summer; this warms the 

stream, reduces the amount of habitat, and reduces the number of cutthroat in the dewatered reach

Ward Creek 

Ø Two culverts on NFSR 373 internally fragment the westslope cutthroat trout population

Ø High road density in the lower half of the watershed (2.8 miles/square mile), with 47 sediment 

contributing crossings 

Piquett Creek 

Ø On private land, the historic riparian willow community has been converted to pasture

Ø The culvert on NFSR 49 isolates the cutthroat trout population from Piquett Creek

Britts Creek 

Ø High road density in the watershed (3.8 miles/square mile)

Castle Creek

Ø The culvert on the middle crossing of NFSR 49 internally fragments the westslope cutthroat trout 

population and isolates the fish in the upper half of Castle Creek

Ø Summer water temperatures are warmer than reference conditions

East Piquett Creek 

Ø High road density in the watershed (3.1 miles/square mile), with 11 sediment contributing 

crossings

Ø Past riparian clearcutting along the south side of East Piquett Creek has reduced riparian overstory 

shade on the stream channel in spots

Ø Summer dewatering on private land impedes and sometimes blocks the connection to Piquett Creek 

Ø The NFSR 731 culvert internally fragments the westslope cutthroat trout population and isolates 

the fish in the upper half of East Piquett Creek

Ø The culvert on NFSR 13411 isolates a few cutthroat trout and about 300 feet of habitat

East Piquett tributary 2.0 

C. INFISH Riparian Management Objectives (RMOs)

The Lower West Fork project is using the four default INFISH RMOs to assess fish habitat conditions

(USDA Forest Service 1995: pgs. A-2 to A-4). These RMOs are: 

Ø Pool frequency

Ø Large woody debris frequency

Ø Wetted width-depth ratio

Ø Water temperature

The numeric values for these RMOs are described in the INFISH Decision Notice (USDA Forest Service

1995: pg. A-4). The current RMO measurements describe the existing conditions and are summarized 

below.
Affected Environment and Environmental Consequences - Fisheries

3.7-8 Lower West Fork Project Final EIS 

All of the streams are meeting the pool frequency RMO with the exception of the West Fork River and 

Baker Creek (Fig. 3.7-2, highlighted in RED). The West Fork River below Painted Rocks Dam currently 

contains 5 pools/mile, which does not meet the RMO (14-18 pools/mile), but does meet the target 

recommended in the Restoration Plan (greater than 4 pools/mile; Montana DEQ, 2005). Highway 

channelization and the reduction in riparian overstory due to highway encroachment and riverfront 

development are the main reasons why pools are in short supply in the West Fork River. The pool 

frequency (82 pools/mile) in Baker Creek is believed to be a natural feature of that stream. Pools will 

increase in Piquett Creek and its burned tributaries over the next several decades as trees killed in the 2007 

Rombo fire fall into streams. 

Figure 3.7-2: Pool Frequency in Fish-Bearing Streams in the Lower West Fork Analysis Area

All of the streams are meeting the large woody debris frequency RMO with the exception of Pierce Creek 

(Fig. 3.7-3, highlighted in RED). This is because NFSR 363 encroaches on the stream channel and 

permanently removes many of the overstory trees along 0.8 of a mile of the stream. The West Fork River 

below Painted Rocks Dam currently contains 25 large wood pieces/mile, which meets the RMO and the 

target recommended in the Restoration Plan (greater than 20 pieces/mile; Montana DEQ, 2005). Though

meeting the RMO, large wood is still lacking in the lower West Fork River and is below historic levels. 

The primary causes are the removal of mature trees for riverfront development and highway encroachment. 

Large woody debris will increase in Piquett Creek and its burned tributaries over the next several decades 

as trees killed in the 2007 Rombo fire fall into streams. 

None of the streams in the Lower West Fork analysis area are meeting the RMO for wetted width-depth 

ratio (Fig. 3.7-4, highlighted in RED). This is not unusual. Since INFISH was implemented in 1995, local 

reference stream data and regional monitoring have consistently shown that the mean wetted width-depth 

parameter ineffectively assesses stream channel health and stability (Overton et al. 1995; Archer et al. 

2006). For example, PACFISH/INFISH effectiveness monitoring data indicates that only 2% of the 

unmanaged streams in the upper Columbia River basin meet the default RMO (Archer et al. 2006). 

Channel stability and dimensions in most of the Lower West Fork streams are similar to reference 

conditions. In Pierce and East Piquett creeks, there are some reaches where channel stability is lower than 

reference conditions. In the absence of mudslides, the 2007 Rombo fire is unlikely to substantially change

stream channel width-depth ratios of the fish-bearing streams in the Piquett Creek drainage. 

The RMO for water temperature is a mean-maximum temperature of less than 15o C over the warmest 7-

day period of the year. Water temperatures were monitored in most of the streams from 2002 to 2006. 

Table 3.7-2 displays the mean-maximum temperature that was recorded for each year that monitoring was 

conducted. Years that exceeded the 15oC RMO are highlighted. 

5

113

82

108

169 170

43

144

98

135

227

147

238

222

185 180

0

50

100

150

200

250

# pools/mile

Tributary RMO is 

> 96 pools/mile

West Fork RMO is 

14-18 pools/mile

Boulder RMO is 26-47 pools/mile

Piquett RMO is 56-96 pools/mile
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-9

Figure 3.7-3: Large Woody Debris Frequency in Fish-Bearing Streams in the Lower West 

Fork Analysis Area

Figure 3.7-4: Wetted Width-Depth Ratio of Fish-Bearing Streams of the Lower West Fork Analysis Area

Based on the data in Table 3.7-2, the Lower West Fork streams can be grouped into three general 

categories: 

Streams that fail to meet the 15oC RMO during all or most years –West Fork River, Pierce Creek, 

Lavene Creek, Boulder Creek, East Piquett Creek, and East Piquett tributary 2.0. With the exception of 

Boulder Creek, water temperatures in these streams are believed to be warmer than their natural 

condition from anthropogenic causes. 

Streams that meet the 15oC RMO about half of the years – Piquett Creek and Ward Creek. Some 

anthropogenic-caused warming could be occurring in the lower reaches of Piquett Creek as a result of 

the high road density and large number of road stream crossings in the lower half of the watershed. 

25

3

165

55

243

225

57

210

164

52

90

106

121

21

143

53

0

50

100

150

200

250

300

# pieces/mile

95

38

25 25 27

32

42

23

32

27

58

21

15

28 28

24

0

10

20

30

40

50

60

70

80

90

100

ratio

RMO for all streams 

is > 20 pieces/mile

RMO for all streams

is a ratio < 10
Affected Environment and Environmental Consequences - Fisheries

3.7-10 Lower West Fork Project Final EIS 

Temperatures in Ward Creek are believed to be near their natural potential, except for times in mid-tolate summer when water is diverted to the stock pastures at Lone Pine.

Streams that meet the 15oC RMO all years

Table 3.7-2: Annual Mean Maximum Water Temperature( ̊C) in Fish-Bearing Streams of the Lower 

West Fork Analysis Area Between 2000 and 2006. (Temperatures greater than 15 ̊C are hi-lighted.)

– Baker Creek, Lloyd Creek, Christisen Creek, Britts Creek, 

Castle Creek, Notch Creek, Piquett tributary 4.2, and Piquett tributary 6.2. Temperatures in these 

streams are believed to be at or near their natural potential. 

1

MP = the distance in miles upstream from the mouth of the stream where the temperatures were 

recorded. 

2

n = no data because temperatures were either not monitored that year, or the thermograph was lost 

or malfunctioned.

In 2008, water temperatures were monitored in Piquett, East Piquett, Castle, and Britts creeks to discern 

any effects from the Rombo fire. Post-fire temperature effects were indistinguishable in Piquett and East 

Piquett creeks. In both streams, there was no distinguishable increase in daily maximum temperatures or 

the diurnal fluctuation between daytime high temperatures and nighttime lows. In Castle Creek, there was 

no distinguishable increase in daily maximum temperatures, but there was a larger fluctuation between 

daytime highs and nighttime lows. In Britts Creek, the daily maximum temperature increased by about 2.5o

C over the 2002-06 average, and the diurnal fluctuation between daytime highs and nighttime lows was 

much larger than pre-fire conditions. This is a typical response of a stream such as Britts Creek where most 

of the headwaters were burned at moderate or high severity. 

D. Sediment

Sediment is not one of the default RMOs in the INFISH strategy, but it is one of the most important habitat 

features for bull trout (Rieman and McIntyre 1993). With the exception of the West Fork River and 

Christisen Creek, the fish-bearing streams in the Lower West Fork analysis area contain sediment levels 

that are similar to reference stream conditions. In the West Fork River downstream of Painted Rocks Dam, 

sediment levels tend to be lower than reference stream conditions because sediment is trapped behind the 

Dam and stored in Painted Rocks Reservoir. The Restoration Plan states, “...even below Deer Creek, 

siltation does not appear to be a problem. To the contrary, sediment targets in the lower river suggest a 

possible coarsening of the stream substrate limiting fine sediment deposition, probably as a result of the 

sediment capture by Painted Rocks Dam” (Montana DEQ 2005: section 3.0, pg. 127). Christisen Creek 

Stream MP1 Elevation 2000 2001 2002 2003 2004 2005 2006

West Fork 1.2 4035’ 18.6 19.1 17.9 19.3 18.3 19.4 n2

West Fork 22.2 4600’ n n 14.7 n 15.6 n 16.4

Pierce 0.4 4200’ 16.0 15.1 16.2 17.7 16.7 16.9 17.3

Baker 1.1 4265’ n 13.6 14.3 14.9 14.4 14.1 14.9

Lloyd 1.0 5033’ n n 11.6 13.0 12.0 12.7 12.8

Christisen 0.7 4793’ n 13.8 n 13.6 13.2 13.5 14.1

Lavene 0.1 4345’ 15.7 15.9 14.6 15.7 16.0 17.0 17.1

Boulder 0.1 4400’ n n 15.6 17.3 17.1 17.3 18.1

Ward 0.1 4412’ n 14.1 14.3 16.4 14.5 14.9 16.7

Piquett 1.3 4168’ n 15.8 14.1 14.9 14.3 15.5 16.3

Piquett 4.7 4425’ n n 12.0 13.4 12.4 12.7 13.6

Piquett trib 4.2 0.1 4357’ n n n n 13.5 12.9 13.8

Piquett trib 6.2 0.1 5420’ n n 9.9 n 10.3 10.8 11.0

East Piquett 0.3 4118’ n n 15.4 16.9 16.3 16.4 17.3

E Piquett trib 2.0 0.1 4935’ n n n n n 15.3 16.7

Britts 0.1 4357’ n n 13.5 14.4 13.5 13.4 14.6

Castle 0.1 4425’ n n 12.1 12.8 12.3 12.3 13.2

Notch 0.1 5690’ n n 8.3 9.2 8.5 9.1 8.9
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-11

contains higher amounts of sand in its substrate than reference streams. This is believed to be a natural 

feature of that stream caused by geology and soil types. On National Forest, the Christisen Creek 

watershed is unroaded and largely unmanaged. Sediment levels in the roaded and unroaded portions of 

Piquett Creek are similar. Coarse sands are common in the substrates in both areas (PF-FISH-001). This is 

believed to be the result of geology and soil types. The July 26, 2009 turbid flow event in Piquett Creek 

temporarily increased the amount of sediment in Piquett Creek and the portion of the West Fork River 

below Piquett Creek. However, this increase is expected to diminish following snowmelt runoff in spring, 

2010. Refer to the Watershed section for more details on the existing condition of sediment. 

3.7.6 ENVIRONMENTAL CONSEQUENCES

For each alternative, five evaluation criteria are used to predict impacts on the fishery. These are:

Ø Sedimentation

Ø Water temperatures

Ø Water chemistry

Ø Woody debris recruitment

Ø Migration barriers

A. Direct and Indirect Effects

With no action, the most likely scenario is that bull trout and westslope cutthroat trout habitat and 

populations in the West Fork River and its tributaries would remain at or near their existing condition, 

assuming that substantial increases in climatic warming or large wildfires do not occur over the next 

decade. Some natural changes would occur in Piquett Creek and its tributaries over the next several 

decades as a result of the 2007 Rombo fire. Based on the literature (Reeves et al. 1995; Gresswell 1999; 

Bisson et al. 2003) and our post-2000 fire monitoring (USDA Forest Service 2003: pgs. 92-98; USDA 

Forest Service 2005: pgs. 89-92), we expect the recruitment of fire-killed trees to create better habitat for 

bull trout and westslope cutthroat trout in the long-term. 

Alternative 1 

Sedimentation

Outside the Piquett Creek drainage, roads (particularly those that encroach on streams) would continue to 

be the source of most of the man-caused sediment entering fish habitat in the West Fork River and its 

tributaries. 

In the Piquett Creek drainage, streams will receive increased sediment inputs from the Rombo fire over the 

next couple of years, in addition to any sediment inputs from roads. Fire-generated sediment inputs are 

limited to the initial flush of ash that entered streams in autumn 2007, the sedimentation that occurred 

following runoff events in 2008, and the July 26, 2009 turbid flow event. Declining sediment inputs are 

expected throughout 2010 and 2011. Fire-generated sediment increases typically disappear about 3 to 4 

years post-fire (Debano et al. 1998; Elliot and Robichaud 2001). If mudslides occur, there is a much higher 

risk of erosion and sediment delivery, and effects could mimic those that occurred in many streams across 

the Forest in 2001 (USDA Forest Service 2001a). The risk of mudslides was highest in 2008, but none 

occurred. The July 26, 2009 turbid flow event may have been triggered by mudslides in the roadless 

headwaters of Piquett Creek, but as of this report, no mudslide locations have been found. There is still 

some risk of mudslides occurring in 2010 and beyond, but that risk will be much diminished due to

vegetation regrowth and the disappearance of hydrophobic soils on the severely burned slopes (Elliot and 

Robichaud 2001; USDA Forest Service 2000b: section 4.3, pg. 17). Following the 2000 fires, most of the 

mudslides on the Forest occurred in 2001, the first year post-fire. The latest occurred in 2003, three years 

post-fire. Post-fire sediment increases could temporarily decrease trout numbers and production in the 

most severely burned reaches in the Piquett Creek drainage between 2008 and 2011, especially if streams 

are affected by mudslides (Sestrich 2005). However, local monitoring (USDA Forest Service 2003: pgs.
Affected Environment and Environmental Consequences - Fisheries

3.7-12 Lower West Fork Project Final EIS 

92-98; USDA Forest Service 2004a: pgs. 110-116) and research (Sestrich 2005) demonstrates that native 

trout populations are resilient to fire, with most westslope cutthroat trout and bull trout populations 

recovering to their pre-fire levels within three years after a fire. 

The July 26, 2009 turbid flow event caused visible and measurable sediment deposition in the West Fork 

River below Piquett Creek. Other than that event, the Rombo fire has not produced visible deposition in 

the river. The sediment deposited by the July 26 event is expected to persist until the spring of 2010 when 

high flows will flush and rout the sediment downstream. By summer 2010, sediment levels in the West 

Fork River are expected to approximate pre-event conditions, assuming that additional turbid flow events 

or mudslides do not occur. 

Water Temperatures 

Water temperatures in the West Fork River and its tributaries, except for Piquett Creek drainage, would 

remain at or near their existing levels. If temperature increases do occur over the next decade, they would 

result from climatic warming, not Forest Service management activities. 

In the Piquett Creek drainage, the reduction in shade caused by the 2007 Rombo fire has altered the water 

temperatures regimes in several streams. In 2008, temperatures were monitored in Piquett, East Piquett, 

Castle, and Britts creeks to discern any effects from the Rombo fire. Post-fire temperature effects were 

indistinguishable in Piquett and East Piquett creeks. In both streams, there was no distinguishable increase 

in daily maximum temperatures or the diurnal fluctuation between daytime high temperatures and 

nighttime lows. In Castle Creek, there was no distinguishable increase in daily maximum temperatures, but 

there was a larger fluctuation between daytime highs and nighttime lows. In Britts Creek, the daily 

maximum temperature increased by about 2.5o C over the 2002-06 average, and the diurnal fluctuation 

between daytime highs and nighttime lows was much larger than pre-fire conditions. This is a typical 

response of a small stream such as Britts Creek where most of its headwaters were burned at moderate or 

high severity. Temperatures were not monitored in Notch Creek in 2008, but it likely responded in a 

similar manner as Britts Creek. In Britts and Notch creeks, post-fire temperature increases may last longer

than a decade because of the considerable extent of moderate and high severity fire in their headwaters 

(Dunham et al. 2007). The 2008 post-fire temperature data from the Piquett Creek drainage was consistent 

with the data collected across the Forest following the 2000 fires (Sestrich 2005; Mahlum et al. 2008; 

USDA Forest Service 2002: pgs. 92-96; USDA Forest Service 2003: pgs. 99-102; USDA Forest Service 

2004a: pgs. 119-124; USDA Forest Service 2005: pgs. 94-100; USDA Forest Service 2006: pgs. 112-117) 

and elsewhere in the western United States (Dunham et al. 2007; Gresswell 1999). Increases in stream 

temperatures have the potential to negatively affect native trout species (Dunham et al. 2003), particularly 

where westslope cutthroat trout and bull trout compete against introduced brook trout (Dunham et al. 

2002). The 2008 data suggests that post-fire temperatures in Piquett and East Piquett creeks are unlikely to 

play a significant role in the competitive struggle between native trout and brook trout. The Rombo fire 

had an indistinguishable effect on water temperatures in the West Fork River. 

Water Chemistry

Water chemistry in the West Fork River and its tributaries, except for the Piquett Creek drainage, would 

remain at or near existing levels. Climatic warming may alter water chemistry to a small degree over the 

next decade, but these changes would occur independently of Forest Service management activities. The 

limited Forest Service herbicide spraying that currently occurs in the Lower West Fork analysis area is not 

measurable in fish-bearing streams. 

In the Piquett Creek drainage, post-fire increases in nutrients (primarily nitrogen and phosphorus from ash, 

leaching and eroded soils) are expected to steadily decrease back down to their pre-fire levels as vegetative 

cover grows back on the burned soils. By summer 2010 (three years post-fire), nutrient inputs from the 

burned area should be similar to pre-fire levels (Gresswell 1999). 

Woody Debris Recruitment 
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-13

Outside of the Piquett Creek drainage, woody debris recruitment to streams would likely continue at or near 

its existing rate. As a result, fish habitat complexity would be maintained at or near its existing condition. 

In the Piquett Creek drainage, a large number of fire-killed trees will fall into Piquett Creek and its 

tributaries over the next several decades (Young 1994; Minshall et al. 1997; Gresswell 1999). This 

recruitment of large wood to streams will create more pool habitat, new areas of spawning and rearing 

habitat, increased habitat complexity, and hiding cover for native trout (Reeves et al. 1995; Gresswell 1999; 

Bisson et al. 2003). All of these changes are beneficial to bull trout and westslope cutthroat trout. 

Following fire, the increase in large wood is a compensatory mechanism that helps offset the short-term 

negative impacts caused by increased sediment and warmer stream temperatures (Gresswell 1999). 

Migration Barriers

The current fish migration patterns would not change under the No Action alternative. No barriers to fish 

movement would be created or removed. 

Under Alternative 2, bull trout and westslope cutthroat trout habitat and populations in the West Fork River 

and its tributaries would continue on a trend similar to the existing condition. Long-term reductions in 

habitat quality or changes in population numbers, age-class structure, or size distributions would not likely

occur. Any changes that may occur are likely to be indistinguishable from the existing condition, and too 

small to measure. 

Alternative 2 

In tributaries of the West Fork River, the short-term effects would likely include low levels of sediment

delivery from roads to streams. The most likely places where sediment would be delivered to fish habitat 

are: (1) directly downstream of the fish culvert replacement sites; and (2) the portion of Pierce Creek that 

NFSR 363parallels closely. Westslope cutthroat trout are present in those areas, but not bull trout. Of 

those areas, sediment deposition would only be visible and measurable directly downstream of the culvert 

replacement sites. The effect on westslope cutthroat trout would be a temporary reduction (less than 9 

months) in habitat quality and displacement of a few fish from the first 600 feet of stream below each 

culvert replacement. In Pierce Creek, sediment inputs mobilized by log truck traffic would cause localized 

reductions in the quality of westslope cutthroat trout spawning and rearing habitat. With mitigation, 

sediment inputs generated by hauling are likely to be too small to be seen or measured. In the rest of the 

tributaries, RHCA buffers would filter out sediment and limit inputs to amounts that would have negligible 

effects on bull trout and westslope cutthroat trout habitat and individuals. 

Sediment inputs from West Fork River tributaries would have a negligible effect on bull trout and 

westslope cutthroat trout habitat and individuals in the West Fork River. The West Fork River below 

Painted Rocks Dam is a large, stable, cobble/boulder-dominated channel with low amounts of sediment. 

Any sediment inputs from the tributaries would be minute and dilute compared to the natural sediment load 

of the river. On the west side of the river, Lavene Creek is the only tributary that is capable of contributing 

sediment to the river throughout the year. The rest of the tributaries on the west side are only capable of 

contributing sediment to the river during high flow periods because of various sediment-trapping features 

on private land such as summer dewatering (Pierce, Baker, Christisen, Lloyd), swamps along the highway 

(Pierce, Lloyd, Ward), or private ponds (Baker). On the east side of the river, Piquett Creek would not 

contribute measurable amounts of sediment to the West Fork River. The sediment deposited by the July 

26, 2009 turbid flow event is expected to have no detectable effect on this project because that sediment 

will have been flushed and routed downstream out of the area well before Alternative 2 is implemented. 

With fuel reduction activities such as those proposed in Alternative 2, there is always some risk that the 

activities would cause more lasting damage to the fishery than the impact of a wildfire (Rieman and 

Clayton 1997; Riggers et al. 2001). Man’s activities in the past have often resulted in a low-grade, negative 

impact on the fishery that persists for many years (i.e. a “press” disturbance), while fire imposes an intense 

but short-term disturbance that dissipates in a few years (i.e. a “pulsed” disturbance). This is particularly 
Affected Environment and Environmental Consequences - Fisheries

3.7-14 Lower West Fork Project Final EIS 

true when management involves new road construction in riparian areas. This concern was voiced in 2001 

by the Western Montana Level I Bull Trout Team when they stated, “...the real risk to fisheries is not fire 

itself, but rather the existing poor condition of our watersheds.” and “...fuel reduction projects that involve 

large-scale thinning and logging can have more harmful effects than the effect of fire itself” (Riggers et al. 

2001). It is true that fuel reduction activities can have harmful effects on the fishery if they are 

implemented in a manner that does not adequately protect water quality. In addition, if water quality is 

degraded, the impact on the fishery will usually last longer and be more detrimental than the disturbance 

caused by wildfire. That being said, each project must stand or fall on its own merits. Just because a 

project involves fuel reduction and logging does not automatically mean that it will be harmful to fish. 

Alternative 2 has been designed in a manner that would adequately protect water quality and the fishery 

because it contains the following elements:

Ø Timber harvest, landings, temporary roads, and tracked line machine trails would not occur in 

RHCAs.

Ø There would be no construction of permanent roads. 

Ø All yarding would comply with Region 1 soil quality standards. 

Ø The valley bottom haul roads are graveled. 

Ø 10.1 miles of road would be decommissioned and 19 miles of road would be stored. This would 

eliminate 22 sediment-contributing culverts and reduce sediment by approximately 27 tons 

annually.

Ø Herbicide spraying would occur on a very limited basis and would incorporate numerous 

mitigation measures designed to protect water quality

By incorporating all of these elements, Alternative 2 is unlikely to degrade water quality or harm the 

fishery. The rationale for this prediction is supported by the following analysis of the evaluation criteria. 

Sedimentation

There are seven activities in Alternative 2 that have the potential to deliver sediment to fish habitat. These 

are: (1) tractor and skyline yarding; (2) log landings; (3) log truck traffic; (4) temporary roads and tracked 

line machine trails; (5) prescribed burning; (6) decommissioning and storing roads; and (7) replacing fish 

barrier culverts. The potential for each of these sediment sources to impact the fishery is analyzed below. 

Yarding and log landings

Most of the scientific literature reviewing forestry-related stream sedimentation indicates that roads are the 

predominant source of sediment in streams, not yarding or log landings (Megahan 1972; Schnackenburg 

and McDonald 1998; Luce and Black 2001a and 2001b; Jordan 2006). Several studies (Belt et al. 1992; 

Davies and Nelson 1994) found that erosion from logging units rather than roads could significantly 

contribute sediment in certain situations, but most of the documented stream impacts occurred in clearcut 

units with narrow or no buffer strips, or sediment transported from channelized sources. Alternative 2 does 

not propose clearcuts, and RHCA buffers that range from 100 to 300 feet wide would protect all streams. 

Delivery of sediment from channelized sources is not a threat because all of the potential channels for 

sediment delivery in the analysis area are RHCAs and would be protected by buffers. The RHCA buffers 

: Tractor skid trails, skyline corridors, and log landings are prone to erosion 

because they remove vegetation and expose soil. However, because their locations are outside of RHCAs, 

sediment from these disturbed areas is unlikely to cross into and filter through the RHCA buffers, and enter 

streams (USDA Forest Service 2005: pgs. 74-75; USDA Forest Service 2006: pgs. 76-77, 81-83). Forest 

fisheries biologists and hydrologists walked all of the RHCA buffers in more than 130 Burned Area 

Recovery salvage units between 2002 and 2007, and never observed sediment crossing into adjacent RHCA 

buffers (USDA Forest Service 2006: pgs. 81-82). The RHCA monitoring occurred within several weeks of 

harvest, and one and two years after harvest in 22 tractor and skyline units (USDA Forest Service 2004a: 

pgs. 90-93). Numerous log landings were monitored during the Burned Area Recovery project, and 

sediment delivery to streams was not observed (USDA Forest Service 2006: pg. 82). 
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-15

would substantially reduce the risk of sedimentation from yarding and landings (USDA Forest Service 

2004a: pgs. 90-93; USDA Forest Service 2005: pgs. 74-75; USDA Forest Service 2006: pgs. 76-77, 81-83). 

The Disturbed WEPP model estimates that the harvest units in Alternative 2 (i.e. skid trails, skyline 

corridors, and landings) would not contribute measurable amounts of sediment to streams. The probability 

of sediment reaching streams ranged between 0% and 7%, depending on the unit. Refer to the Watershed 

section for more details on the Disturbed WEPP model and sedimentation. 

With the protection afforded by intact RHCA buffers, the monitoring data, literature, and model predictions 

all suggest that yarding and landings have a low potential to contribute sediment to fish habitat. Log 

yarding and landing operations would have a low potential of causing sedimentation and degrading fish 

habitat because of the capacity of the RHCA buffers to filter sediment. If any sediment would get into 

streams from skid trails, skyline corridors, or landings, the quantities are likely to be too small to be visible 

or measurable. 

Log truck traffic

Roads that closely parallel streams are more likely to deliver sediment to fish habitat during hauling than 

upland roads not located in valley bottoms. The scientific literature almost universally agrees that the most 

likely point of sediment delivery occurs where roads cross streams and road segments are within 300 feet of 

streams, with some exceptional cases noted (Elliot and Foltz 2001; Luce and Black 2001b). In Alternative 

2, there are three valley bottom haul roads that are located within 300 feet of fish-bearing streams for at 

least 1000 feet of their length. These are: 

: Forest roads are commonly recognized as the primary source of human-caused sediment 

that accumulates in streams (Furniss et al. 1991), and log truck traffic on forest roads produces more 

erosion and higher road sediment contributions compared to light, noncommercial traffic (Luce and Black 

2001b). Of all the timber harvest-related activities in Alternative 2, log truck traffic would have the most 

potential to add sediment to fish habitat (USDA Forest Service 2005: pg. 76). This potential depends on 

two factors: (1) the proximity of the haul road to streams; and (2) the condition of the road during the log 

haul. 

Ø NFSR 363 along Pierce Creek (0.8 of a mile)

Ø NFSR 49 along Piquett Creek (3.5 miles)

Ø NFSR 5630 along Lavene Creek (0.4 of a mile) 

Of these three roads, NFSR 363 along Pierce Creek has the highest sedimentation potential during log 

hauling. NFSR 363 is located within 50 feet of Pierce Creek for 0.8 of a mile, and the riparian filter strip 

separating the road from the stream is steep and very narrow. This close proximity makes aquatic resource 

protection difficult, and leaves few effective BMPs to reduce road surface sediments. The encroached 

segment of NFSR 363 was gravel surfaced and BMP upgraded in 2004. It was used during log haul on the 

Frazier Interface project in 2005-06 with good results (PF-FISH-005; USDA Forest Service 2006: pg. 76). 

Because of the BMP upgrades, sediment contributions from NFSR 363 have probably been reduced to the 

extent possible without paving or relocating the road. Burroughs and King (1989) studied sedimentreduction effectiveness from graveling and found a 70-79% reduction in sediment after applying a 4-inch 

lift of crushed rock. The quality of crushed rock matters - Foltz (1996) found poor quality aggregate 

produced 4-17 times as much sediment as high quality aggregate when tested with log truck traffic on the 

Willamette National Forest, which has a much wetter climate than the Lower West Fork analysis area. 

NFSR 49 is located in the valley bottom of Piquett Creek for about four miles, but the valley is wide 

enough that most of the road is up against the toe of the slope, more than 150 feet from Piquett Creek. The 

grade of NFSR 49 is gentle, and Piquett Creek is separated from the road by a relatively flat, well vegetated 

buffer of mature spruce/fir forest. Most of the valley bottom segment of NFSR 49 was graveled in 2008. 

Potential sediment contributing segments of NFSR 49 total about 0.3 of a mile. These consist of: (1) a 

couple of spots in the lower two miles of NFSR 49 where meanders of Piquett Creek approach within 50 

feet of the road; (2) two bridge crossings of Piquett Creek; and (3) two culvert crossings of small, perennial 
Affected Environment and Environmental Consequences - Fisheries

3.7-16 Lower West Fork Project Final EIS 

tributaries. All of the potential sediment contributing segments were graveled in 2008. The bridge and 

culvert crossings contribute negligible amounts of sediment because the gentle grade of the road does not 

allow runoff to build up enough energy to transport sediment off the road and through the adjacent riparian 

filter. Because of its good riparian filter strip, log hauling on NFSR 49 is unlikely to contribute measurable 

amounts of sediment to bull trout and westslope cutthroat trout habitat in Piquett Creek. 

NFSR 5630 is located in the Lavene Creek RHCA for 0.4 of a mile and has two culvert crossings at the 

upstream end of the segment. NFSR 5630 is unlikely to contribute measurable amounts of sediment to 

Lavene Creek because the road was gravel surfaced and BMP upgraded in 2006, and is separated from the 

stream by a flat, well-vegetated riparian filter strip that averages about 100 feet in width. 

NFSR 5629 is located within 100 feet of Frazier Draw for 0.4 of a mile. However, the encroached segment 

is graveled, and Frazier Draw does not contain fish or contribute sediment and water to downstream fish 

habitat. The rest of the roads that would receive log truck traffic in Alternative 2 would be located more 

than 300 feet away from fish-bearing streams for nearly all their lengths. For this reason, hauling on these 

roads would not deliver measurable amounts of sediment to fish habitat. Croke et al. (2005) studied 

road/stream connectivity in forested terrain and found a mean sediment travel distance of 291 feet below 

road culverts. Burroughs and King (1989) observed that 90% of sediment flows below road fill slopes 

traveled less than 88 feet, suggesting that filter strips work if they are wide enough and have sufficient 

obstacles to slow channelized flows. Collector roads that would be used to haul logs in the action 

alternatives, and the estimated number of log truck trips per road are listed in Table 3.7-3. 

Table 3.7-3: Estimate of Log Truck Traffic on Road Segments

Road Name Road No. Estimated Log-Truck Trips

Alt. 2 Alt. 3

Pierce Creek 363 365 Same as 2

Baker-Christisen Loop 5629 225 Same as 2

Lavene Creek 5630 404 Same as 2

Barn Draw 373 127 Same as 2

East Piquett 731 159 22

Piquett-Pine Ridge 5720 215 0

Eastside Piquett 5723 76 46

Upper Eastside Piquett 5724 178 82

Piquett Creek 49 1 628 150 1 NFSR 49 is the arterial road in the Piquett Creek drainage that would collect all of the log trucks 

driving down NFSRs 731, 5720, 5723, and 5724. Not all roads used for haul are listed in this table; 

only the collector roads with the most traffic.

The condition of a road during hauling is the other factor, along with its proximity to streams, which 

determines the likelihood of a haul road delivering sediment to streams. Log truck traffic ruts the road 

prism, which reduces the ability of the road to effectively drain during storms and runoff periods, and 

increases erosion. The amount of rutting and erosion that occurs depends on the weather. Generally, dry, 

well-drained and well-surfaced roads withstand rutting from truck traffic and release very little sediment to 

the surrounding land. When hauling occurs during wet periods or spring break-up, however, roads often 

develop substantial ruts and can deliver large amounts of sediment to nearby streams for several weeks. 

Burroughs and King (1989) estimated an increase of about 200% in road surface erosion rates if rutting 

occurs along with heavy truck traffic. Foltz (1996) found that logging traffic on wet roads produced 

between two and 25 times the sediment as no traffic. Luce and Black (2001b) noted various researchers 

provided a range of traffic-related road surface erosion increases over no traffic from double to 30 times. 

On the Bitterroot NF, the rutting that occurred on the North Rye road in March 2002 delivered enough 

sediment to North Rye Creek to keep the stream turbid for several weeks (USDA Forest Service 2003: pg.

81). On the Rye Creek road, log trucks managed by the State created ruts and similar sediment problems in 

March 2003 (USDA Forest Service 2003: pg. 81). Over the past five years, careful timber sale 
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-17

administration, and diligent monitoring effectively reduced rutting and stream sedimentation from 

encroached road segments during log hauling (USDA Forest Service 2003: pgs. 81-82; USDA Forest 

Service 2005: pg. 76). Examples include: 

Ø the second (2002-03), third (2003-04), and fourth (2004-05) winters of the Burned Area 

Recovery log haul along the Guide Creek (311), Laird Creek (370), and North Rye (321) roads 

(USDA Forest Service 2003: pgs. 81-82; USDA Forest Service 2004a: pg. 95; PF-FISH-004); 

Ø the 2004 log haul from the West Camp salvage sale on the Hughes Creek (104-A) and West Fork 

Camp Creek (8112 and 729) roads (USDA Forest Service 2004a: pg. 88); 

Ø the 2005-06 log haul from the Frazier Interface stewardship sale on the Pierce Creek (363) road 

(PF-FISH-005; USDA Forest Service 2006: pg. 76); 

Ø the 2005-06 log haul from the Beaver Woods timber sale on the Woods Creek (5669) road 

(USDA Forest Service 2006: pg. 77); 

Ø the first (2006-07) and second (2007-08) winters of Lil’ Lyman and Painted Rocks West timber 

sale log haul on the Guide Creek (311) and Coal Creek (5660) roads (PF-FISH-006); and 

Ø the first (2007-08) winter of Middle East Fork log haul on the Jennings Camp Creek (723) road 

(PF-FISH-006). 

Straw bale check dams would be installed as mitigation to prevent sediment produced during log haul from 

reaching streams and degrading fish habitat on NFSRs 363, 49, and 5630. On NFSR 363, the check dams 

would be installed below the outlets of the ditch relief culverts and other drainage features such as drivethrough dips. On NFSRs 49 and 5630, the check dams would be installed at the stream crossings, in the 

ditches that drain into the stream crossings, and below the outlets of any ditch relief culverts. The check 

dams would be maintained throughout the duration of haul. The straw bale check dam mitigation has been 

successfully used on other encroached haul roads to prevent sediment from entering streams (PF-FISH-005; 

PF-FISH-006). It provides an extra measure of protection for keeping sediment out of nearby streams. 

Monitoring indicates that the straw bale check dams, installed along the encroached segments of NFSRs 

311 and 363, trapped and prevented about 44 gallons and 45 gallons of road sediment from entering Guide 

Creek and Pierce Creek, respectively, during recent log hauls (PF-FISH-005; PF-FISH-006). 

The monitoring data and literature indicate that log hauling is the harvest activity with the most potential to 

add sediment to fish habitat in Alternative 2. The haul road that is most likely to contribute sediment is the 

portion of NFSR 363 that closely parallels Pierce Creek. Pierce Creek contains spawning and rearing 

habitat for westslope cutthroat trout. With careful sale administration, monitoring by specialists, and 

installation of the straw bale check dams, hauling-generated sediment inputs to Pierce Creek would be 

reduced to the point they would not be visible in the stream bottom or measurable. At these low levels we 

would be unable to detect an effect on westslope cutthroat trout population numbers in Pierce Creek. The 

sporadic nature of hauling traffic would also help minimize the potential sediment deposited in Pierce 

Creek. Hauling would last several years, with heavier periods of hauling punctuated with extended periods 

of little or no hauling. Stream sediment would be flushed and diluted during periods of light use, especially 

when at least one spring runoff flow occurs during the lifetime of the haul. The portions of NFSRs 49 and 

5630 along Piquett and Lavene creeks have better riparian filter strips and consequently, a lower risk of 

contributing sediment than NFSR 363. The rest of the haul roads in Alternative 2 are farther than 300 feet 

from streams for most of their lengths. Because of their upland locations and the small sizes of the streams 

the roads cross, hauling is unlikely to deliver enough sediment to those streams to have an adverse effect on 

fish habitat and populations downstream of the crossings. 

Temporary Roads and Tracked Line Machine Trails: Alternative 2 would construct 1.4 miles of new 

temporary road and 1.7 miles of tracked line machine skid trails. Alternative 2 would also re-use 0.8 mile 

of “temporary road” that consists of old, drivable road templates. All of the temporary road and tracked 

line machine trails would avoid RHCAs. Tracked line machine trails require level pads, 20 by 20 feet at 

125-150 foot intervals, for the line machine to stand on. These pads are usually built along a ridge where 
Affected Environment and Environmental Consequences - Fisheries

3.7-18 Lower West Fork Project Final EIS 

access is easy and timber can be cabled up to the ridge. Tracked line machine trails may require excavation 

in spots to eliminate excessive side slopes and ensure safe machine travel. All of the temporary roads and 

tracked line machine trails are likely to be present on the landscape for 1-2 years before they are recontoured and seeded. 

Forest fisheries biologists and hydrologists monitored four temporary roads in the Burned Area Recovery 

project that were constructed on uplands outside of RHCAs, and recontoured after use (USDA Forest 

Service 2006: pg. 82). Sediment did not move more than a few feet off the road shoulders, and there was 

no sediment delivery to streams (USDA Forest Service 2006: pg. 82). Tracked line machine trails were 

constructed, used, and recontoured in the recently completed Frazier Interface and Painted Rocks West 

timber sales. Similar to temporary roads, monitoring found that sediment did not move more than a few 

feet beyond the shoulders of the trail, and because of their considerable distances from the nearest RHCAs, 

there was no sediment delivery to streams (USDA Forest Service 2006: pg. 76; USDA Forest Service 2007: 

pg. 95). 

Modeling conducted for the Middle East Fork project (PF-WAT-23) found that temporary roads and 

tracked line machine trails are only likely to contribute sediment to streams when they cross RHCAs. None 

of the temporary roads or tracked line machine trails in Alternative 2 would enter RHCAs. In light of the 

monitoring data and model predictions, it is unlikely that temporary roads and tracked line machine trails in 

Alternative 2 would contribute sediment to streams. 

Prescribed Burning

Forest fisheries biologists and hydrologists monitored several of the recent, large prescribed burns that have 

been completed on the Forest (USDA Forest Service 1998: pg. 69; PF-FISH-007). Their monitoring 

indicates that most of the RHCA area does not burn during prescribed fires. Where fire does back down 

into the RHCAs, it tends to burn at low severity and in a spotty pattern. Rarely does prescribed fire burn all 

the way down to the edges of the stream banks. 

: The prescribed burning activities in Alternative 2 would consist of a mix of helicopter 

and manually-ignited fires, and in certain units, manual thinning and slash pile burning concurrent with 

timber harvest prior to burning. The prescribed burns would not consume all of the duff material 

throughout the units. Maintaining a duff layer preserves the soil infiltration capacity and reduces the 

potential of overland flow and sediment delivery to streams (Robichaud 2000; Wondzell and King 2003). 

Recovery of herbaceous vegetation after prescribed burning occurs within 1-2 growing seasons. 

Vegetation stabilizes the soil, filters sediment, and reduces sedimentation potential. 

The scientific literature examining the effects of prescribed fire on aquatic ecosystems is limited, but the

available research consistently indicates that prescribed burning has less severe impacts on aquatic 

ecosystems than wildfire (Gresswell 1999; Robichaud 2000; Wondzell and King 2003; Beche et al. 2005; 

Elliot and Vose 2005; Harris et al. 2007). Prescribed burns are typically conducted during times of the year 

when humidity and fuel moisture in riparian areas are relatively high, which reduces fire intensity and 

retards flame spread in riparian zones (Dwire and Kauffman 2003). Beche et al. (2005) monitored the 

effects of a low-to-moderate intensity prescribed fire that was ignited in the riparian area along a Sierra 

Nevada stream. They found either no effects or only short-term effects on water chemistry, water quality, 

macroinvertebrates, and physical stream habitat one year after the fire. Harris et al. (2007) reported 

prescribed fires had similarly minimal impacts in the Blue Mountains of eastern Oregon and Washington. 

The Disturbed WEPP model estimates that the prescribed burning in Alternative 2 would contribute

sediment to fish-bearing streams, ranging from a low of 0.5 ton in Boulder Creek to a high of 16.4 tons in 

Lavene Creek. The probability of sedimentation occurring is 0-3% in East Piquett Creek, 7% in Boulder 

Creek, 0-23% in Lavene Creek, 0-27% in Pierce Creek, and 13-30% in Piquett Creek. Refer to the 

Watershed section for more details on the Disturbed WEPP model and its predictions. 

The monitoring data, literature, and model results indicate that the amount of sediment delivered to streams 

from prescribed fire depends on the severity of the burn in the RHCA. Because the prescribed fires would 
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-19

occur when moisture and humidity levels in the RHCAs are relatively high, large patches of high severity 

burn would not be created in the RHCAs. For this reason, sediment entry points on streams would be 

widely distributed, and the amount of sediment entering streams would likely be too small to be visible or 

measurable. Mitigation measures required by the U.S. Fish and Wildlife Service in their programmatic 

biological assessments for manual thinning (USDI Fish and Wildlife Service 2000) and prescribed fire 

(USDI Fish and Wildlife Service 2001) would be implemented during prescribed burning activities. With 

these mitigations, we expect prescribed burning would generate negligible sediment increases to fish 

habitat (USDI Fish and Wildlife Service 2001: pg. 6). 

Road Decommissioning and Storage

Monitoring of recently decommissioned and stored roads on the Bitterroot NF indicates that the removal of 

culverts and recontouring of stream crossings has caused negligible sediment input to streams (USDA 

Forest Service 2005: pg. 82; USDA Forest Service 2006: pg. 84; PF-FISH-008). By three years after 

implementation, the decommissioned and stored roads contained good vegetative cover, with the fastest 

regrowth occurring on north slopes and higher elevations (USDA Forest Service 2006: pg. 98), and the 

slowest regrowth occurring on low elevation south slopes where weeds are more prevalent (USDA Forest 

Service 2004a: pg. 103; USDA Forest Service 2005: pg. 82; PF-FISH-008). 

: Decommissioning and storing roads would increase sediment in the 

short-term when culverts are removed and road fills are recontoured. These activities reduce long-term 

sediment production as vegetation regrows and soil is no longer exposed. Under Alternative 2, culverts 

would be removed on two fish-bearing crossings (Pierce Creek and East Piquett tributary 2.0), and 20 nonfish bearing crossings of 1st and 2nd order streams. Sixteen of the crossings are sediment contributing 

points. Most of the streams with culverts proposed for removal would be dry or contain minimal water at 

the time of culvert removal. Foltz et al. (2007) reported that removing a culvert during road obliteration 

contributed an average of 67 kilograms (kg) of sediment to streams without use of a straw bale sediment 

trap, and an average of 1.6 kilograms with a straw bale sediment trap. For 20 of the 22 culverts, the nearest 

fish habitat is located more than a thousand feet downstream of the crossing, and in many cases, it is more 

than a mile downstream. 

The scientific literature reviewing roads almost universally agrees that watersheds with higher road 

densities, roads in use, and road-stream crossings have higher amounts of sediment in their streams 

compared with watersheds that have lower levels of road influence (Furniss et al. 1991; Quigley and 

Arbelbinde 1997; Baxter et al. 1999). Few studies, however, have examined whether decommissioning 

reverses these effects. On the Flathead National Forest, McCaffery et al. (2007) found less sediment in 

watersheds where decommissioned roads had a high amount of vegetation regrowth versus watersheds 

where decommissioned roads contained only sparse vegetation, and concluded that decommissioning roads 

that lead to a high level of revegetation probably reduces sediment in streams. Wegner (1999) documented 

a 48% decline in sediment and 16% increase in bull trout redds in a Kootenai National Forest watershed in 

the 5 years following road decommissioning. 

The road decommissioning and storage in Alternative 2 would reduce road sediment inputs to streams in 

the analysis area by about 27 tons per year. These reductions would commence when healthy vegetative 

cover returns to the obliterated road prisms, which typically occurs within three years of obliteration. Refer 

to the Watershed section for more information on sediment reductions from decommissioned and stored 

roads. 

Based on the monitoring data, literature, and model predictions, the decommissioning and storing of roads 

in Alternative 2 would contribute small amounts of sediment to streams in the immediate vicinity where 

culverts are removed and road fills recontoured. Because of the upland locations of the culverts, most of 

the sediment is unlikely to ever enter fish habitat. In Pierce Creek and East Piquett tributary 2.0, 

sedimentation would occur in westslope cutthroat trout habitat directly downstream of the NFSR 13466 

(Pierce) and 13411 (East Piquett tributary 2.0) culvert removal sites. Deposition would be restricted to the 

immediate crossing area, and straw bale sediment traps would be installed as mitigation to limit sediment 
Affected Environment and Environmental Consequences - Fisheries

3.7-20 Lower West Fork Project Final EIS 

inputs. A few cutthroat trout may vacate their territories below the road crossings for short periods of time 

while the culverts are being removed, but once the turbidity settles out of the water column, those fish 

would reoccupy their territories and resume social behaviors. Although difficult to measure at the 

watershed scale, the sediment reductions that occur as a result of road decommissioning and storage would 

improve habitat for bull trout and westslope cutthroat trout over the long-term. 

Culvert Replacements

The sediment deposition caused by the culvert replacement remains until the next scouring peak flow 

occurs, which is typically an 8-9 month period between summer low flows and the next spring’s peak 

flows. During that time, fish spawning and rearing habitat, hiding cover, and aquatic insect food supply is 

locally reduced and degraded in the first 600 feet of stream below the culvert replacement site (NMFS

2006: pgs. 63-64). After the peak flows flush the sediment from the area, deposition is usually no longer 

visible, and habitat quickly rebounds to, or close to, the pre-disturbance condition. 

: Since 2000, the Bitterroot NF has replaced about 45 culverts for fish passage 

purposes. This activity is also common on other National Forests throughout the northwestern United 

States. Studies conducted by the Bitterroot NF (USDA Forest Service 2001b: pgs. 128-132), Lolo NF 

(Casselli et al. 2000), Nez Perce NF (Vuono 2007), and others (NMFS 2006: pgs. 54-59) found that 1-2 

tons of sediment were contributed to streams during culvert replacements. Most of the deposition occurs in 

the first 300 feet of stream below the culvert and is usually not visible more than 600 feet downstream of 

the culvert (NMFS 2006: pg. 64). In this analysis, we have conservatively estimated that each culvert 

replacement would contribute two tons of sediment to streams, which is at the high end of the range of the 

measurements reported in the literature (NMFS 2006). 

In Alternative 2, the temporary reductions in westslope cutthroat trout spawning and rearing habitat 

described above would occur at two sites in Lavene Creek, two sites in Ward Creek, and one site in Castle 

Creek. At each site, less than 600 feet of spawning and rearing habitat would be affected. Based on the 

recent Bitterroot NF track record (e.g. about 1-2 replacements per year), the high cost of replacing culverts, 

and the Forest’s considerable backlog of culverts needing replacement, it would likely take about a decade 

to replace all of the fish culverts in Alternative 2. Given the intermittent timing of the work, along with the 

temporary and localized nature of the effects, it is unlikely that westslope cutthroat trout spawning and 

rearing habitat would be adversely affected in any of the streams. 

When a stream is first diverted back through a new culvert, the fish that reside within the first 600 feet of 

stream below the culvert are exposed to sub-lethal concentrations of suspended sediment for a couple hours 

(NMFS 2006: pgs. 57-58). Plumes of suspended sediment are usually not visible more than 600 feet below 

the culvert (NMFS 2006: pg. 55). The fish exposed to the suspended sediment plumes may experience 

increased physiological stress and reduced feeding rates, and some will respond by vacating their territories 

and moving downstream away from the plume (Berg and Northcote 1985; NMFS 2006: pgs. 57-58). Most 

lethal and sub-lethal effects described in the literature are associated with long-term exposure to high 

suspended sediment concentrations. Berg and Northcote (1985) demonstrated that exposure to short-term 

pulses of turbidity altered the social behavior of juvenile coho salmon (Oncorhynchus kisutch). During 

turbid periods (30 to 60 non-turbulent unit (NTU)), territorial behavior broke down, and subordinate fish 

captured more prey. Territorial behavior and social structure were re-established when turbidity decreased 

to below 20 NTU. In Alternative 2, fish would only be exposed to sub-lethal suspended sediment 

concentrations (30 to 60 NTU) for less than two hours. Concentrations are likely to decrease below 20 

NTU within two hours after a culvert is replaced (NMFS 2006: pgs. 57-58). 

In Alternative 2, exposure to sub-lethal plumes of turbidity would force some westslope cutthroat trout to 

vacate their territories downstream of the culverts for less than two hours. Once the turbidity clears from 

the water column, the trout would move back into the vacated areas and re-establish their territories and 

social behavior. The sediment and turbidity produced by the culvert replacements would only affect a 

small percentage of the westslope cutthroat trout that reside in Lavene, Ward, and Castle creeks. Based on 

our fish population monitoring data, we estimate that less than 50 cutthroat trout would be exposed to 
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-21

suspended sediment at each of the sites. Given the intermittent timing of the culvert replacements, along 

with the temporary and localized nature of the effects, individual westslope cutthroat trout are unlikely to 

die because of exposure to suspended sediment or temporary reductions in habitat quality. 

Bull trout would not be affected by the sediment or turbidity produced by culvert replacements. Bull trout 

are present in only one of the streams (Castle Creek) where a replacement would occur, and in that 

instance, the nearest bull trout habitat occurs more than a mile downstream of the culvert (Fig. 3.7-5). For 

the other four culvert replacements in Alternative 2, the nearest bull trout habitat (juvenile rearing habitat in 

the river) occurs 0.5 of a mile downstream (the two Lavene Creek culverts) and 0.7 of a mile downstream 

(the two Ward Creek culverts). Ward Creek flows into a large swamp on the west side of the highway, 

where it deposits its sediment before it reaches an overflow culvert and flows under the highway into the 

West Fork River. The National Marine Fisheries Service concluded in their Biological Opinion on stream 

crossing replacement/removal that sediment produced by culvert replacement activities is unlikely to have a 

significant negative effect on listed salmon and steelhead trout and their habitat located more than 600 feet 

downstream of the replacement/removal site (NFMS 2006: pgs. 55, 63-64, 73-75). Foltz et al. (2007) 

reported that sediment concentrations 810 meters downstream of culverts were similar to sediment 

concentrations above culverts for the entire excavation period. In Alternative 2, all of the culvert 

replacements would occur at least 2600 feet (800 meters) upstream of bull trout habitat. The nearest bull 

trout habitat consists of juvenile rearing habitat in the West Fork River, which is occupied at very low 

densities in a large river bottom with low sediment levels. For these reasons, we conclude that bull trout 

would be too far from the culvert replacement sites to be negatively affected by sediment or turbidity. 

Water Temperatures 

Numerous studies have demonstrated that the loss of streamside vegetation can cause elevated stream

temperatures during periods of summer low flow, and larger daily fluctuations in maximum and minimum 

stream temperatures (Beschta et al. 1987; see list of authors in Beschta and Taylor 1998; Burton 2005; 

Sestrich 2005; Dunham et al. 2007). The primary cause of stream temperature increases is the increased 

amount of solar radiation striking the water surface (Beschta 1997). In Alternative 2, there would be no 

logging in the RHCAs. The only vegetation treatments allowed in the RHCAs would be prescribed burning

and manual thinning of sub-merchantable conifer thickets more than 50 feet from stream channels. The 

RHCA buffer widths would encompass at least one site potential tree height (100 feet) around intermittent 

streams, 1-2 site potential tree heights (150 feet) around perennial non-fish bearing streams, and three site 

potential tree heights (300 feet) around fish-bearing streams. These widths would be sufficient to protect 

essentially all of the vegetative shade (known in the literature as “angular canopy density”) on stream 

channels (USDI Fish and Wildlife Service 1998: Appendix 5). 

The use of prescribed fire near streams may create small, scattered openings in the riparian canopy. 

However, the creation of large, contiguous openings in the riparian canopy would not occur because there 

is a low potential for crown fire in the moister riparian areas during the burning windows (USDA Forest 

Service 1998: pgs. 10, 69). The mitigations in the U.S. Fish and Wildlife Service’s programmatic 

biological assessments for prescribed fire (USDI Fish and Wildlife Service 2001) and manual thinning 

(USDI Fish and Wildlife Service 2000) are incorporated into Alternative 2. These mitigations would 

maintain stream shading at or near current levels, and thereby maintain water temperatures in streams 

(USDI Fish and Wildlife Service 2000; 2001b). 

In addition to the direct removal of streamside shade, other potential mechanisms of stream warming 

include increased peak flows that cause mass erosion events and channel widening (Beschta and Taylor 

1988), sediment deposition that occurs on a large enough scale to cause channel widening (Rhodes et al. 

1994), and alterations of the microclimate in and adjacent to the riparian area (Moore et al. 2005; USDI 

Fish and Wildlife Service 1998: Appendix 5). The commercial thinning and prescribed burning treatments 

in Alternative 2 would not remove enough canopy cover to increase peak flows that would then trigger 

mass erosion events and channel widening. Sediment deposition also would not occur on the scale needed 

to widen stream channels and increase exposure to sunlight. 
Affected Environment and Environmental Consequences - Fisheries

3.7-22 Lower West Fork Project Final EIS 

Figure 3.7-5: Distribution of Bull Trout and Westslope Cutthroat Trout in the Lower West Fork 

Analysis Area
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-23

As for the risk of microclimate alterations increasing stream temperatures, the RHCA buffers would 

encompass the microclimate “caution zones” (the 100-year floodplain plus one site potential tree height) 

recommended in the bull trout Biological Opinion (USDI Fish and Wildlife Service 1998: Appendix 5). 

The commercial thinning and prescribed burning treatments in the uplands surrounding the RHCAs under 

Alternative 2 would not increase air temperatures in the RHCAs to the level required to warm stream water 

(USDI Fish and Wildlife Service 1998: Appendix 5). 

Replacing or removing culverts for fish passage removes the shade from streams for a distance of less than 

50 lineal feet per culvert. This increases exposure to solar radiation at that road crossing for at least a 

decade until shrubs and/or trees grow back that are large enough to shade the stream channel. In 

Alternative 2, this would occur at two road crossings on Lavene Creek, two road crossings on Ward Creek, 

and one road crossing each on Britts, Castle, East Piquett tributary 2.0, and Pierce Creeks. At that small 

end of a scale, it is unlikely that the increased exposure to sunlight would measurably increase downstream 

water temperatures. Also, the effect would diminish over time as vegetation grows back on the disturbed 

road fills. 

Individually or cumulatively the processes described above would not cause measurable increases in stream 

temperatures. Therefore, Alternative 2 would maintain the cold temperature regimes in the West Fork 

River and its tributaries needed by bull trout and westslope cutthroat trout. 

Water Chemistry

Herbicide applications can potentially harm fish by killing them outright, causing sublethal changes in 

behavior or physiology, or reducing the availability of macroinvertebrate prey. The scientific literature is 

generally lacking for the potential environmental effects of herbicides on fish species; consequently, this 

risk analysis relies heavily on modeling, extrapolation, and inference from the available published studies. 

This risk analysis also tiers to the Selway-Bitterroot Wilderness Invasive Plants Management Project Draft 

Environmental Impact Statement (SBW Weeds DEIS) (USDA Forest Service 2008d). Much of the 

information presented in this risk analysis is a summary of more detailed information presented in the SBW 

Weeds DEIS. 

The potential impact of herbicides on fish and other aquatic organisms is a function of two factors: 

Ø How toxic is the herbicide?

Ø What is the concentration that the organism would be exposed to?

The first part of this risk analysis is to investigate the toxicity of the herbicides that are proposed for use. In 

Alternative 2, the following herbicides could be used: 

Ø Aminopyralid

Ø Chlorsulfuron

Ø Clopyralid

Ø Dicamba

Ø Glyphosate Rodeo

Ø Glyphosate Roundup

Ø Imazapic

Ø Metsulfuron methyl

Ø Picloram

Ø Sulfometuron methyl

Ø Triclopyr-TEA

Ø 2,4-D

These herbicides are characterized by relatively low aquatic toxicity. Their specific toxicity characteristics 

are discussed in Appendix I of the SBW Weeds DEIS (USDA Forest Service 2008d), and pages 26-48 of 

the SBW Weeds Fisheries Biological Assessment (BA) (USDA Forest Service 2008b). Table 13 in the BA 

(on page 28) summarizes the aquatic toxicology of the herbicides that could be used in Alternative 2. Of 

the herbicides that are most commonly used on the Bitterroot NF and likely to be used in Alternative 2, 

picloram is the most toxic to fish, while 2,4-D, aminopyralid, and clopyralid are several orders of 

magnitude less toxic (USDA Forest Service 2008b: pg. 28; USDA Forest Service 2008d: pg. 3.3-24). 

Toxicity to aquatic biota can be quantified with two different parameters: 
Affected Environment and Environmental Consequences - Fisheries

3.7-24 Lower West Fork Project Final EIS 

The “96-hour Lethal Concentration” (LC50).: The 96-hour LC50 refers to the concentration of a chemical 

that is lethal to 50 percent of the fish exposed at that concentration for a period of 96 hours. The lower the 

LC50,, the more toxic the chemical. Although the 96-hour LC50 is frequently used as a toxicity standard, 

fifty percent fish mortality is usually not acceptable. Therefore, a better parameter to assess toxicity to fish 

is the “No Observed Effect Level” or “No Observed Effect Concentration”, which are described below. 

The “No Observed Effect Level” (NOEL)

Because there are frequently no long-term test results that have established NOEL/NOEC levels for a given 

species, the U.S. Environmental Protection Agency (EPA) recommends that the 96-hour LC50 be divided 

by 20 in order to establish a conservative “safety factor” threshold to protect endangered species. 

: The “No Observed Effect Level” or “NOEL” is the highest 

concentration of toxicant to which organisms are exposed in a full life-cycle or partial life-cycle test that 

causes no observable effect on survival, growth, or reproduction of the test population. This would mean 

there is no significant difference between the test solution and the control, as determined by hypothesis 

testing. The NOEL is also referred to as the “No Observed Effect Concentration” or “NOEC” level. 

Table 13 in the SBW Weeds Fisheries BA (USDA Forest Service 2008b: pg. 28) lists the 96-hour LC50 and 

the LC50 /20 for the herbicides proposed for use in Alternative 2. Table 3.3-10 in the SBW Weeds DEIS 

(USDA Forest Service 2008d: pg. 3.3-24) lists the 96-hour LC50, the LC50 /20, and the NOEL/NOEC levels, 

where available. 

For all of the herbicides except picloram and 2,4-D, the LC50/20 was the most conservative parameter, and 

it was used to establish thresholds for the maximum number of acres that could be annually sprayed in a 6th

code watershed. For picloram and 2,4-D, the NOEL was more conservative than the LC50/20. Therefore, 

the NOEL was used instead of the LC50/20 to set the maximum acre thresholds for picloram and 2,4-D. 

The second part of this risk analysis involves estimating the possible herbicide concentration in streams. 

Field studies of herbicide spray operations have shown that herbicide input to streams can range from nondetectable amounts to 6 percent of the amount applied (Monnig 1988). To determine the delivery rate of 

herbicides to streams it is important to distinguish between infiltration-dominated sites and runoffdominated sites, and analyze all of the potential pathways in which herbicides could get into streams. 

Rice (1990) reviewed numerous studies involving picloram runoff to streams, and concluded that a 

maximum of 10% of the herbicide applied to a runoff-dominated site could reach a stream within six hours 

of a heavy rainstorm. On infiltration-dominated sites, it was determined that a maximum of only 1% of the 

applied herbicide could reach a stream within 24 hours of a heavy rainstorm. Rice’s percentages were 

incorporated in the calculations used to determine the maximum number of acres that could be sprayed 

annually in each 6th code watershed. 

In Alternative 2, there are four possible pathways in which herbicides could get into streams: 

Ø Direct application

Ø Drift from areas treated near streams

Ø Binding to soil particles which are eroded from terrestrial sites by overland flow

Ø Leaching through the soil 

Direct application is the pathway that can introduce the greatest quantity of herbicides to streams, and have 

the most pronounced effect on water quality and aquatic organisms. However, because of the prohibition 

of herbicide spraying within 15 feet of water and the absence of aerial spraying, direct application of 

herbicides to streams is unlikely to occur unless there is some sort of accidental spill, leak, or improper 

storage and handling of chemicals. These incidents can be avoided by properly following the mitigation 

measures of herbicides and spray equipment storage, handling, cleaning, and transporting. 

Drift, overland flow on bare soils, and leaching are pathways in which herbicides can indirectly enter 

streams. Drift from nearby spraying is similar to direct application but concentrations would be lower and 

the probability of impact reduced. Overland flow on bare soils has the potential to deliver herbicides to 
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-25

streams, particularly if large rainstorms occur soon after roadside ditches are sprayed. If the mitigation 

measures are properly followed, the risk of overland flow is much reduced. Leaching of herbicides through 

the soil profile is the least likely pathway for herbicides to enter streams because, depending on the 

chemical, they tend to break down as they move through the soil profile. Table 3.3-9 in the SBW Weeds 

DEIS (USDA Forest Service 2008d: pg. 3.3-23) and Table 14 in the SBW Weeds Fisheries BA (USDA 

Forest Service 2008b: pgs. 29-30) summarize the movement potential for herbicides. 

In Alternative 2, a maximum of 300 acres would be sprayed annually with herbicides in the Lower West 

Fork analysis area, for a period of 10 years. Spraying would focus on high risk areas for weed spread such 

as haul roads, skid trails, log landings, temporary roads, decommissioned and stored roads, and portions of 

prescribed fire units. Spraying would occur either by truck or by hand (i.e. backpack). There would be no 

aerial spraying. 

The mitigation measures for herbicide spraying are lengthy, and are listed in Chapter 2 of this document. 

The most important mitigations for aquatic organisms are the ones that apply to herbicide applications in 

RHCAs. These are summarized in Table 3.7-4. 

Several conservative assumptions were purposely built into this risk analysis in order to err on the side of 

aquatic protection. Those assumptions include:

Ø All 300 acres (i.e. the maximum acreage allowed per year) would be sprayed in a single day –

not over a 1-2 month period as would actually occur

Ø In each 6th code watershed, it was assumed that 50% of the herbicide would be applied on 

infiltration-dominated sites (1% of the herbicide would enter streams) and 50% on runoffdominated sites (10% of the herbicide would enter streams). In reality, most of the herbicide 

would be applied on infiltration-dominated sites, and with proper adherence to the mitigation 

measures, the amount of herbicide that actually enters streams would be much less than what we 

calculated. 

Ø The picloram application rate of 1.0 pound of active ingredient per acre corresponds to four pints 

of liquid picloram per acre, which is the maximum recommended rate. In most cases, a lesser 

amount would be used. Picloram is the herbicide of greatest concern for aquatic biota. 

Ø The lowest annual stream flow was calculated for the affected watersheds and used to determine 

maximum concentrations of herbicides in the streams. The lowest stream flow of the year 

generally occurs in mid September, prior to the onset of fall rains. All of the herbicide spraying 

would actually occur in May through August, when stream flows are higher than those used in 

the calculations. The result is that the amount of potential dilution of chemicals is 

underestimated in our calculations. 

Using these conservative assumptions, we calculated the maximum allowable acreage that could be sprayed 

annually – without exceeding the lethal amount (i.e. the NOEL/NOEC for picloram and 2,4-D; the LC50 /20 

for all other proposed herbicides) for trout – for each 6th code watershed in the Lower West Fork analysis 

area. Those acreages are displayed in Table 3.7-5. 

We emphasize that the calculations used to come up with the maximum allowable acres in Table 3.7-5 are 

intentionally conservative in order to err on the side of aquatic protection. The likelihood of actually 

reaching the NOEL/NOEC or LC50 /20 concentrations in stream water would be very low. Actually, it is 

unlikely that we would be able to detect any herbicide in stream water because of the small acreage (i.e. 

maximum of 300 acres in any given year) that would be spread out across a broad area and conducted over 

a period of 1-2 months or longer. For example, Watson et al. (1989) monitored picloram spraying in a 

riparian area in Montana and could not detect picloram in the stream water at the one part per billion

detection limit. The Bitterroot NF conducted a limited amount of water quality monitoring during 2004 

and 2005 large acreage aerial spray operations, and did not detect any herbicide chemicals in nearby 
Affected Environment and Environmental Consequences - Fisheries

3.7-26 Lower West Fork Project Final EIS 

streams at the 0.0001 part per million detection limit (PF-FISH-010, FISH-011). Drift cards set up along 

riparian corridors also failed to detect any droplets of herbicide (PF-FISH-010). 

Table 3.7-4: Herbicide Use Restrictions in RHCAs

Distance from 

Live Water

Maximum Allowable Wind 

Speed

Application Activity Allowable Herbicides and 

Formulations1

0 feet N/A

Chemicals will not be used 

over live water, including 

water standing or running in 

ditch lines

None

< 15 feet

5 mph and blowing away 

from the direction of the 

water

Spot applications only2 with 

aquatically approved 

chemicals

Spray must be pointed away 

from the water

2,4-D

Glyphosate3

> 15 feet

5 mph and blowing away 

from the direction of the 

water

Spot applications 2 or 

focused spraying of target 

species with aquatically

approved chemicals – may 

include treating larger 

patches of weeds or multiple 

patches in close proximity

Spray must be pointed away 

from the water

2,4-D

Glyphosate

Triclopry

Aminopyralid

Metsulfuron methyl

Clopyralid

Dicamba

Imazapic

> 50 feet 5 mph

Spot applications 2 or 

focused spraying of target 

species – may include 

treating larger patches of 

weeds or multiple patches in 

close proximity 

No broadcast spraying 

within 300 feet of water

All chemicals listed above 

as well as picloram4

> 100 feet Less than 10 mph

Same as > 50 feet

No broadcast spraying 

within 300 feet of water

All chemicals listed above 

as well as:

2,4-D/Clopyralid blend

Chlorsulfuron 1 Blended brand name or tank mixed chemicals would be limited within 300 feet of water

2 spot application includes spot spraying, wicking, wiping, dripping, painting, or injecting of individual plants

3 Trade name glyphosate products, not containing surfactants that can be used within the 0-15 foot buffer of 

live water include: Aqua Neat, Aquamaster, Glyphos Aquatic, and Rodeo 4 Picloram would not be used within 50 feet of any stream for any reason, and would generally not be used 

within 100 feet of streams unless other herbicides are ineffective in controlling certain weed species such as 

leafy spurge or rush skeletonweed 5 The chemical Sulfometuron methyl (Oust) would be used on areas > 300 feet from water
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-27

Table 3.7-5: Maximum Annual Sprayable Acreage for each Herbicide with No Observable Effect (or equivalent) to Trout

Delivery rate is 50% infiltration and 50% runoff for each subwatershed Amino- pyralid Chlor-sulfuron

Clopyralid

Dicamba

Glyphosate Rodeo

Glyphosate

Roundup

Imazapic

Meth-sulfuron 

Methyl

Picloram

Sulfo-meturon 

Methyl

Triclopyrl TEA

2,4-D

Chemical Application Rate (lbs./acre) 0.11 0.02 0.5 1.0 1.5 1.5 0.2 0.03 1.0 0.045 1.0 1.0

Median Lethal Concentration (LC50-ppm) 100 40 100 135 923 22 100 150 0.8-26 150 199 240

NOEL or NOEC (ppm) 3.2 20 100 0.29 1.20 104 10

Median Lethal Concentration/20

(LC50/20-ppm) 5 2 5 6.8 46 1.1 5.0 7.5 7.5 10 12

HUC 6 HUC 6 Name Watershed 

(acre) Maximum acres that could be treated annually at the No Observable Effect Level (or equivalent) for trout

0204 Nez Perce Fork 23,917 11,033 24,273 2,427 1,651 7,476 178 7,585 60,682 70 6,473 2,427 2,427

0302 Boulder Creek 13,511 8,336 18,339 1,834 1,247 7,386 134 5,731 45,849 53 4,891 1,834 1,834

0303 Piquett Creek 20,672 8,888 19,533 1,955 1,330 6,022 143 6,110 48,883 57 5,214 1,955 1,955

0304 Trapper Creek 18,196 10,900 23,981 2,398 1,631 5,662 176 7,494 59,952 70 6,395 2,398 2,398

0305 West Fork Bitterroot 

River (Lower) 22,063 8,356 18,383 1,838 1,250 15,483 135 5,745 45,957 53 4,902 1,838 1,838
Affected Environment and Environmental Consequences - Fisheries

3.7-28 Lower West Fork Project Final EIS 

In Alternative 2, a maximum of 300 acres would be sprayed in the analysis area in any given year. For all 

of the herbicides except picloram, 300 acres is a much smaller area than the maximum allowable acres 

shown in Table 3.7-5 that meet the NOEL/NOEC (or equivalent) level. Because picloram has higher 

aquatic toxicity than the other herbicides, its maximum allowable acres are considerably lower than those 

of the other herbicides. 

Based on the possibility that herbicides may enter a stream or other water source, herbicides could have a 

short-term effect on fish and other aquatic organisms in isolated areas. Adhering to the RHCA spray 

restrictions in Table 3.7-4 would reduce the risks of herbicides moving into surface waters or leaching into 

ground water. The RHCA restrictions should ensure that spray drift or herbicide runoff does not adversely 

affect listed aquatic species, their prey, and non-target riparian vegetation. Application procedures would 

comply with Forest Plan/INFISH standard RA-3 and State of Montana Best Management Practices. 

Herbicide volatilization and spray drift are the primary mechanisms of off-target movement. Ground 

application minimizes spray drift because spray nozzles can be in close proximity to target species and the 

ground. 

For all species of trout, the proposed rates of herbicide applications and treatment areas under Alternative 2 

would be below the threshold rates for lethal effects, and mortality of individual fish is not expected given 

proper adherence to the mitigation measures and label requirements that reduce or eliminate the risk of 

accidental application of herbicides into streams. Uncertainty exists, however, on the level of herbicides 

that may reach streams and their potential for causing sub-lethal effects to trout. Sub-lethal effects are 

those that don’t result in mortality, but could affect elements related to the overall health and fitness of 

individual fish. We cannot conclude with certainty that herbicides would not reach streams that support 

bull trout and westslope cutthroat trout spawning and rearing. Sub-lethal effects of the proposed herbicides 

have not been thoroughly investigated. They may include loss or modification of physiological or 

behavioral functions that could affect survival, reproductive success, growth, or migratory behavior. 

Information on sub-lethal effects for a number of the functions, however, does exist for some herbicides

(USDA Forest Service 2004b).

Herbicides can indirectly affect fish populations by altering the populations of other organisms upon which 

fish are dependent. Table 3.3-12 in the SBW Weeds DEIS (USDA Forest Service 2008d: pgs. 3.3-32 to 

3.3-33) provides toxicity data for aquatic organisms other than fish. The data suggests that herbicides are 

generally less toxic to lower orders of aquatic taxa than to fish species. Although the species listed in Table 

3.3-12 are not the only aquatic organisms found in waters affected by this project, the U.S. Fish and 

Wildlife Service and EPA use them as indicators of a wide range of aquatic organisms. The aquatic 

organisms generally have higher tolerances to toxic materials than do fish, so keeping herbicide 

applications below the maximum allowable acres listed in Table 3.7-5 would result in low risk to these 

organisms. The proposed rates of herbicide applications and treatment areas under Alternative 2 would be 

below the threshold rates for lethal effects. 

Woody Debris Recruitment 

The recruitment of large woody debris in stream channels is the most important process that creates and 

maintains complex habitats, pools, and hiding cover for bull trout and westslope cutthroat trout on the 

Bitterroot NF. The RHCA buffer widths would protect the woody debris recruitment “caution zones” 

described in the bull trout Biological Opinion (USDI Fish and Wildlife Service 1998: Appendix 5), and 

would be wide enough to maintain essentially all of the woody debris recruitment to stream channels that 

naturally occurs in riparian corridors, wetlands, and landslide prone areas (Naimen et al. 2000). 

The prescribed burning in Alternative 2 may increase woody debris recruitment to streams on a small and 

localized scale if the fires are hot enough to kill some patches of overstory trees near streams. If this 

occurs, recruitment of large wood would be spotty at best. Beche et al. (2005) observed little recruitment 

of large wood to a Sierra Nevada stream one year after a low-to-moderate intensity prescribed fire in the 

riparian area. Monitoring on the Bitterroot NF indicates that prescribed fires have rarely produced large 
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-29

areas of moderate or high severity burn in riparian areas, and recruitment of large wood to streams has been 

incidental (USDA Forest Service 1998: pg. 69; PF-FISH-007). 

Thinning sub-merchantable conifer thickets more than 50 feet from stream channels would have a 

negligible effect on present and future woody debris recruitment (USDI Fish and Wildlife Service 2000). 

The trees that would be cut would be too small and located too far from streams to contribute to fish 

habitat. The dense growing conditions would also prevent their growing large enough to provide stream 

shade or habitat complexity in the future. Thickets of sub-merchantable conifers also restrict the growth of 

dominant trees that are most important for woody debris recruitment and shade (USDI Fish and Wildlife 

Service 2000). 

For the reasons described above, Alternative 2 would maintain the present and future recruitment of large 

wood to streams. Therefore, it would also maintain the complex habitats needed by bull trout and 

westslope cutthroat trout in the lower West Fork tributaries. 

Migration Barriers

Alternative 2 would improve the connectivity of westslope cutthroat trout populations in five tributaries by 

eliminating seven culvert barriers (5 replacements + 2 removals) that currently block or impede access to 

historic spawning and rearing habitat. Eliminating the seven culvert barriers would reduce the 

fragmentation of cutthroat populations and re-connect access to about 3.4 miles of historic spawning and 

rearing habitat. 

Bull trout are only present in one of the streams (Castle Creek) where a culvert barrier would be eliminated. 

The nearest bull trout in Castle Creek occurs greater than one mile downstream of the replacement site. For 

that reason, there would be no immediate benefits to bull trout population connectivity. 

Replacing or removing the seven culvert barriers would not occur all at once. At current funding levels, it 

would likely take about a decade to replace or remove all of the culverts. The culvert barriers that affect 

the most fish and restrict access to the most spawning and rearing habitat would be eliminated first. The 

priority order for implementation would be: 

Ø Castle Creek, middle crossing of NFSR 49 (1.3 miles of habitat opened up)

Ø Lavene Creek, middle and upper crossings of NFSR 5630 (1.5 miles of habitat opened up)

Ø Ward Creek, lower and upper crossings of NFSR 373 (0.3 of a mile of habitat opened up)

Ø Pierce Creek, NFSR 13466 (removal) (0.2 of a mile of habitat opened up)

Ø East Piquett tributary 2.0, NFSR 13411 (removal) (0.1 of a mile of habitat opened up)

The streams listed above contain small populations of genetically pure westslope cutthroat trout. The 

populations consist of several hundred (Pierce, East Piquett tributary 2.0) to several thousand (Castle, 

Lavene, Ward) individuals generally spread over less than 2 miles of suitable habitat. The culvert barriers 

cause internal

The two ditch screens (Ward Creek and Baker Creek) that would be installed in Alternative 2 are expected 

to reduce the number of westslope cutthroat trout that become trapped and perish in the Ward and Baker 

ditches each summer. 

fragmentation of their respective populations. For example, in Lavene Creek, the culvert 

under the West Fork Highway is a barrier that completely isolates all of the cutthroat in Lavene Creek from 

the West Fork River. In addition to the highway culvert, the culverts upstream on the Forest internally 

fragment the cutthroat population into three smaller segments. Alternative 2 would eliminate the internal 

fragmentation of cutthroat populations that currently exists in Lavene, Castle, Ward, Pierce, and East 

Piquett tributary 2.0. In each stream, the benefits to their respective populations would include potentially 

increased production of young, resiliency to disturbance, and genetic diversity within the populations 

(Rieman et al. 1993). This is especially important when you consider that some of the populations (Lavene 

and Pierce Creeks, for example) would remain isolated from the West Fork River until the West Fork 

Highway culvert barriers are removed, which could take decades. 
Affected Environment and Environmental Consequences - Fisheries

3.7-30 Lower West Fork Project Final EIS 

In Alternative 3, the short-term effects on the fishery would be indistinguishable from those described for 

Alternative 2, except the risk of contributing sediment to bull trout and westslope cutthroat trout habitat in 

Piquett Creek and its tributaries would be lower since there would be less timber harvest and log hauling in 

the Piquett Creek watershed. In the long-term, Alternative 3 would provide more benefits to the fishery 

because of the greater amount of road decommissioning and storage. This conclusion is based on the 

following predicted effects to the evaluation criteria. 

Alternative 3 

Sedimentation

Potential sources of sediment under Alternative 3 would be the same as those described for Alternative 2. 

On the west side of the West Fork River, the effects to the fishery from sediment would be 

indistinguishable from those described for Alternative 2. The proposed harvest and burning treatments on 

the west side of the river are very similar in Alternatives 2 and 3. 

On the east side of the river, the risk of stream sedimentation would be lower in Piquett Creek and its 

tributaries because there would be less timber harvest and log hauling in the Piquett Creek watershed. 

There would also be more roads decommissioned and stored, and more sediment-contributing road 

crossings eliminated, which would reduce sediment inputs to streams in the long-term. 

Water Temperatures 

The effects on water temperatures would be the same as those described for Alternative 2. Alternative 3 

would maintain the existing temperature regimes in the West Fork River and its tributaries and the cold 

water needed by bull trout and westslope cutthroat trout. 

Water Chemistry

The effects on water chemistry would be the same as No Action (Alternative 1). No herbicide treatments 

would occur in Alternative 3. 

Woody Debris Recruitment 

The effects on woody debris recruitment and fish habitat complexity would be the same as those described 

for Alternative 2. Alternative 3 would maintain the present and future recruitment of large wood to 

streams, and the complex habitats needed by bull trout and westslope cutthroat trout. 

Migration Barriers

Alternatives 2 and 3 propose the same fish culvert replacements, removals, and fish screens. Therefore, the 

effects on fish population connectivity would be the same. Alternative 3 would improve the connectivity 

and reduce the fragmentation of westslope cutthroat trout populations in the Lower West Fork analysis 

area. 

B. Cumulative Effects

The cumulative effect predictions made below are excerpts from a detailed fisheries cumulative effects 

worksheet that was completed and is available in the project file (PF-FISH-009). 

The most likely scenario with no action is that bull trout and westslope cutthroat trout populations and 

habitat would continue on a trend similar to the existing condition, assuming that substantial increases in 

climatic warming or large wildfires do not occur over the next decade. The recruitment of large wood that 

will occur in Piquett Creek and its tributaries over the next several decades because of the Rombo fire will 

improve bull trout and westslope cutthroat trout habitat in the long-term. 

Alternative 1

The highest potential for cumulative effects would come from log hauling on the portion of NFSR 363 that 

closely parallels Pierce Creek. Sediment contributions from hauling on NFSR 363 under Alternative 2 

Alternative 2 (Proposed Action)
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-31

could potentially combine with two other sediment sources: (1) sediment contributions from the Trapper 

Bunkhouse log haul; and (2) sediment contributions from a poorly drained, private logging road that was 

constructed close to Pierce Creek in 2006. The Trapper Bunkhouse project proposes to haul about 116 

truckloads of logs on NFSR 363, which would occur concurrently with the Alternative 2 log haul. The 

private road currently contains little vegetation to slow erosion, and it would continue to contribute 

sediment during the Alternative 2 log haul. The combination of log haul in Alternative 2, the Trapper 

Bunkhouse log haul, and the low standard private road would cumulatively increase sediment contributions 

to Pierce Creek above current levels for several years, and this has the potential to reduce westslope 

cutthroat trout spawning and rearing habitat in Pierce Creek during the duration of the Alternative 2 log 

haul. 

Although there is potential for Alternative 2 to cumulatively reduce to quality of westslope cutthroat trout 

spawning and rearing habitat in Pierce Creek, the reductions in habitat are unlikely to occur across a large 

enough area or over long enough duration to cause a measurable decline in westslope cutthroat trout 

numbers. There are two reasons for this: (1) the encroached segment of NFSR 363 was graveled surfaced 

and BMP upgraded in 2004; and (2) Pierce Creek does not contain excessive sediment levels. The BMP 

upgrades have reduced, but do not entirely prevent erosion from the road surface and sediment delivery to 

nearby Pierce Creek. Log truck traffic under Alternative 2 would increase road sediment contributions to 

Pierce Creek while the haul is active, and possibly for as long as 1-5 years after the haul has been 

completed (Black and Luce 1999). However, with careful sale administration, monitoring by specialists 

and installation of straw bale check dams at the sediment contributing points, sediment generated by log 

hauling under Alternative 2 would not be measurable in Pierce Creek. For example, the combination of 

monitoring and straw bale mitigation was effective in preventing direct sediment inputs from NFSR 363 

during the recent Frazier Interface log haul (PF-FISH-005; USDA Forest Service 2006: pg. 76). In 

conclusion, we would be unable to measure a decline in the westslope cutthroat trout population from 

cumulative sediment increases because Pierce Creek does not have excessive sediment, and the straw bale 

check dams would provide additional protection. 

If intense thunderstorms, heavy spring runoff, or unusually large rain-on-snow events occur while hauling 

is active on NFSR 363, erosion could be accelerated and cause visible amounts of sediment escaping the 

straw bale check dams and entering westslope cutthroat trout habitat. If that occurs, the quality of 

westslope cutthroat trout spawning and rearing habitat could be reduced near the outlets of ditch relief 

culverts, or below any fish culverts replaced in the previous year. These reductions would be temporary, 

lasting until the next flushing flow. However, with the protective mitigation afforded by the straw bale 

check dams, it is unlikely that enough sediment would be able to escape the check dams, enter fish habitat, 

and combine with other sediment sources to reduce westslope cutthroat trout population numbers. 

The direct and indirect effects of Alternative 2 treatments would not add significantly to the effects of the 

Rombo fire. Alternative 2 would protect intact RHCAs; therefore, it would not exacerbate the fire-caused 

stream temperature increases that have occurred in the Piquett Creek watershed. The fire-generated 

sediment increases that occur in Piquett Creek, its tributaries, and the West Fork River in 2010-11 could 

potentially occur at the same time as Alternative 2 timber harvest and log hauling. However, the 

combination of project and fire-generated sediment has a low risk of causing a cumulative decline in bull 

trout and westslope cutthroat trout population numbers and habitat conditions. The reasons for this include:

Ø the sediment generated by Alternative 2 is likely to be too small and dispersed to be measurable, 

except in very small areas near the fish culvert replacement sites; 

Ø the fire-generated sediment increases would be disappearing at the same time that Alternative 2 

is just starting to be implemented; 

Ø the sediment deposited by the July 26, 2009 turbid flow event will be gone from the project area 

well before Alternative 2 is implemented. 
Affected Environment and Environmental Consequences - Fisheries

3.7-32 Lower West Fork Project Final EIS 

Sediment from Alternative 2 would not combine with sediment from the Trapper Bunkhouse project or 

other sources to cause measurable changes in fish habitat quality in the West Fork River. The Trapper 

Bunkhouse project would have as little an effect on water quality in the West Fork River as does 

Alternative 2 in this project (USDA Forest Service 2008c). The cumulative effect of the two projects 

would be insignificant – bull trout and westslope cutthroat trout populations and habitat quality would be 

maintained, with negligible risk of contributing to the spread of non-native trout. 

Assuming the picloram maximum allowable acres threshold (Table 3.7-5) is not exceeded in any given 

year, and the mitigation measures and label requirements are properly followed, the cumulative effect of 

herbicide spraying on bull trout and westslope cutthroat trout individuals would be non-lethal. Uncertainty 

exists on the quantity of picloram that may reach streams and its potential for causing sub-lethal cumulative 

effects to trout. If the maximum allowable acres threshold for picloram is exceeded in any given year, then 

the cumulative effect could be lethal to some bull trout and westslope cutthroat trout individuals in the 

Lower West Fork analysis area. Aquatic organisms other than fish generally have higher tolerances to 

picloram than do fish, so the cumulative risk to these organisms is considerably lower. 

The retention of intact RHCA buffers in Alternative 2 would eliminate any cumulative effect on stream 

processes such as woody debris recruitment, habitat complexity, and water temperatures. The RMOs 

would be adequately protected. 

In Pierce Creek, Lavene Creek, and the West Fork River, the cumulative effect of Alternative 3 would be 

indistinguishable from that described for Alternative 2. 

Alternative 3

In Piquett Creek and its tributaries, timber harvest and log hauling under Alternative 3 would produce less 

erosion and potential sedimentation concurrent with Rombo fire-generated sediment increases. Although 

the difference in sediment delivery to streams in Alternatives 2 and 3 would be too small to be measurable, 

Alternative 3 would be more beneficial to the post-fire recovery of the fishery because there would be 

considerably less timber harvest and log truck traffic occurring at the same time as fire-generated sediment 

increases. 

As with Alternative 2, the retention of intact RHCA buffers in Alternative 3 would eliminate any 

cumulative effects on stream processes such as woody debris recruitment, habitat complexity, water 

temperatures, and water chemistry. The RMOs would be adequately protected. 

The bull trout and westslope cutthroat trout populations in the Lower West Fork analysis area are part of 

larger meta-populations that include all of the resident and migratory bull trout and westslope cutthroat 

trout in the West Fork drainage downstream of Painted Rocks Dam. The viability of these metapopulations is considered to be depressed (USDA Forest Service 2000a: pgs. 49-52), primarily because of 

habitat alternations and displacement by non-native trout species (Rieman et al. 1993; USDA Forest 

Service 2003: pgs. 98-99). 

Viability of Bull Trout and Westslope Cutthroat Trout Populations

The action alternatives are unlikely to further compromise the depressed viability status of bull trout and 

westslope cutthroat trout at the analysis area scale (the Lower West Fork analysis area), the cumulative 

effects geographic area scale (the West Fork drainage downstream of Painted Rocks Dam), and the basin 

scale (the Bitterroot River basin). This is because the action alternatives would not alter habitat to the 

measurable degree, or facilitate the displacement of bull trout and westslope cutthroat trout by non-native 

trout. 

C. Fisheries Biological Evaluation

The westslope cutthroat trout is the only Sensitive fish species that occurs in the Lower West Fork analysis 

area. The biological evaluation for westslope cutthroat trout has been incorporated into the effects analysis 
Affected Environment and Environmental Consequences - Fisheries

Lower West Fork Project Final EIS 3.7-33

as directed by USFS Region 1 letter 2670/1950 (August 17, 1995). The following paragraphs summarize 

the determination of effects on westslope cutthroat trout. 

The determination for Alternative 1 is “

Alternative 1 

no impact.” With no action, the most likely scenario is that 

westslope cutthroat trout habitat and populations would remain at or near their existing condition. 

Population viability is unlikely to change from the current depressed condition at both the local population 

scale, and elsewhere on the Forest. 

The determination for Alternative 2 is “may impact individuals or habitat, but will not likely contribute to a 

trend towards federal listing or loss of viability to the population or species.” The rationale for this 

determination is described in the “Direct and Indirect Effects” and “Cumulative Effects” sections for 

Alternative 2. Alternative 2 has a higher risk of adding sediment to westslope cutthroat trout habitat than 

Alternative 3, but with the exception of culverts replaced or removed for fish passage purposes, sediment 

additions under Alternative 2 would not be measurable. The area and types of herbicide applications in 

Alternative 2would be under the threshold rates for lethal effects, and mortality of individual westslope 

cutthroat trout is not expected. There is some potential that individual westslope cutthroat trout could be 

subjected to sub-lethal effects in isolated instances. The most likely scenario with Alternative 2 is that 

westslope cutthroat trout habitat and populations would continue on a trend similar to the existing 

condition. Long-term reductions in habitat quality or changes in population numbers, age-class structure, 

or size distributions would not occur as a result of Alternative 2. Population viability is unlikely to change 

from the current depressed condition at both the local population scale, and elsewhere on the Forest. 

Alternative 2 

The determination for Alternative 3 is “may impact individuals or habitat, but will not likely contribute to a 

trend towards federal listing or loss of viability to the population or species.” The rationale for this 

determination is described in the “Direct and Indirect Effects” and “Cumulative Effects” sections for 

Alternative 3. Alternative 3 would be the most beneficial of the action alternatives for westslope cutthroat

trout because it would have the lowest risk of contributing sediment to habitat affected by the Rombo fire, 

and would achieve the largest reduction in road sediment in the long-term across the analysis area. 

Alternative 3 

Table 3.7-6: Fisheries Sensitive Species Biological Evaluation and Listed Species Biological Assessment 

- Summary of Determination of Effects.

SPECIES STATUS Alt 1 Alt 2 Alt 3

Westslope Cutthroat Trout Sensitive NI MIIH MIIH

NI= No Impact

BI= Beneficial Impact

MIIH= May Impact Individuals or Habitat, but will not likely contribute to a trend towards Federal listing 

or loss of viability to the population or species

LIFV= May Impact Individuals or Habitat with a consequence that the action may contribute towards 

Federal listing or result in reduced viability for the population or species

Prepared by: /s/Michael J. Jakober Date: August 6, 2009

Form 2 (R-1-2670-95)

 

Michael J. Jakober 

Bitterroot NF South Zone Fisheries Biologist
Affected Environment and Environmental Consequences - Fisheries

3.7-34 Lower West Fork Project Final EIS 

3.7.7 CONSISTENCY WITH THE BITTERROOT FOREST PLAN AND OTHER 

REGULATORY DIRECTION

All of the alternatives are consistent with the Bitterroot Forest Plan as amended by INFISH and the other 

fisheries regulatory direction. All of the alternatives would adequately protect the RMOs, native fish, and 

their habitats. All of the activities proposed in RHCAs would comply with INFISH standards and 

guidelines, and programmatic agreements made with the U.S. Fish and Wildlife Service. 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-1

3.8 WILDLIFE 

3.8.1 INTRODUCTION

This section of the DEIS discloses the direct, indirect, and cumulative impacts on threatened, endangered, 

or sensitive wildlife species, as well as management indicator species identified in the Bitterroot National 

Forest Plan (USDA 1987). 

3.8.2 REGULATORY FRAMEWORK

The regulatory framework providing direction for the protection and management of wildlife populations 

and their habitat comes from the following principal sources.

A. Endangered Species Act of 1973 (as amended)

Section 7 of the Endangered Species Act (ESA) directs that actions authorized, funded, or carried out by 

federal agencies do not jeopardize the continued existence of any threatened or endangered species, or 

result in the adverse modification of habitat critical to these species. The Bitterroot National Forest 

(Bitterroot NF) consulted with the United States Fish and Wildlife Service (FWS) and determined there are 

no listed threatened or endangered species on the Bitterroot NF or in the project area. Therefore, a 

Biological Assessment (BA) was not prepared for the Lower West Fork project. Though the Bitterroot NF 

is not considered primary Canada lynx habitat, the Forest Service followed the Northern Region Lynx 

Management Direction Standards and Guidelines Consistency Evaluation Table for Project Specific 

Activities to assess project effects on potential lynx habitat.

B. National Forest Management Act of 1976

The National Forest Management Act (NFMA) provides for balanced consideration of all resources. The 

Forest Service is required to manage for viable populations of native and desired non-native species, and to 

maintain and improve habitat of management indicator species.

C. Bitterroot National Forest Plan (Forest Plan)

The 1987 Bitterroot NF Plan (Forest Plan) in compliance with NFMA establishes Forest-wide management 

direction, goals, objectives, and standards and guidelines for the management of wildlife species and their 

habitats on the Bitterroot NF. Direction covers old growth habitat, management indicator species, sensitive 

species, and threatened and endangered species. 

The Forest Plan requires retention of 25 percent of the big game winter range in thermal cover. Other 

Forest Plan standards related to maintenance of wildlife populations include the amount and distribution of 

old growth habitat by management area (MA), retention of snags, maintenance of elk populations and 

habitat, and management of elk habitat effectiveness (USDA 1987). 

The Forest Plan goal is to provide habitat that supports viable populations of native and desired non-native 

wildlife, and to maintain habitat for the recovery of threatened and endangered species (USDA 1987: II-3). 

Habitat needs of sensitive species and protection of threatened and endangered species is considered in all 

project planning (USDA 1987: II-21). 

3.8.3 AREA OF ANALYSIS

Unless otherwise noted, the wildlife effects are analyzed on National Forest in the Lower West Fork 

analysis area (Figure 1-1 in Chapter 1). The analysis area may change depending on the species, its habitat 

distribution, home range size, linkages between suitable habitats, and model parameters. Changes in the 

analysis area are described in the appropriate Affected Environment section. Since most of the effects of 

proposed activities will be site-specific changes, cumulative effects are broadly evaluated within the Lower 

West Fork analysis area. 
Affected Environment & Environmental Consequences - Wildlife 

3.8-2 Lower West Fork Project Final EIS 

3.8.4 EFFECTS ANALYSIS METHODS

Some elements of wildlife habitat require a detailed analysis and discussion to determine potential effects 

on particular species. Other elements are not affected or the effects are minor and do not influence the 

species or their occurrence. Some effects on species can be adequately addressed through project design. 

In these cases a detailed analysis is not necessary. 

We selected species for detailed analysis if they were present in the project area or their known habitats are 

likely to be affected by the proposed actions. We analyzed old growth habitat and snag habitat because 

these habitat components are crucial to several species and they might be affected by the proposed actions.

We do not analyze in detail the Coeur d’Alene salamander, northern bog lemming, northern leopard frog, 

and the peregrine falcon because the proposed actions would not occur in or affect their habitats.

The data sources used in the effects analysis include field surveys, aerial photographs, and databases. 

Stand level field data relevant to wildlife habitat is contained in Oracle and TSMRS/FACTS databases that 

are compatible with Arc View Geographic Information Systems. The south zone Wildlife Biologist 

reviewed, interpreted, and validated data from the Lower West Fork analysis area through multiple field 

reviews of this project and other projects in the area. 

Forestland bird information is synthesized from the Northern Region Land Bird Monitoring Program data, 

FWS Breeding Bird Survey, and breeding bird information (Bitterroot NF files). The FWS Breeding Bird 

Survey is available on the internet. 

Old growth habitat on the Bitterroot NF, outside of wilderness and roadless areas, was inventoried and 

field-verified using Forest Plan old growth forest criteria and descriptions in Green et al. (1992, errata 

2005). Because the Forest Plan provides criteria by which to determine old growth habitat and does not 

provide a specific old growth definition, there is no conflict with Green et al. (1992, errata 2005) 

descriptions. Green et al. (1992, errata 2005) described old growth habitat characteristics by habitat type 

group (Table 3.8-1). A forest-wide inventory of old growth was completed, however vegetation conditions 

change, especially through insect, disease, and fire activity that are common on the Bitterroot NF. 

Inventory results are disclosed in the Old Growth Habitat section 3.8.5 A. The Wildlife Biologist also 

examined these areas for other wildlife species and their associated habitat.

Elk habitat features were mapped for the Lower West Fork analysis area following the definitions in USDA 

Forest Service (1979). Elk habitat effectiveness, the method of analyzing elk security described by Lyon 

(1983) and specified by the Forest Plan, was evaluated. Elk security was analyzed following the technique 

developed by Hillis et al. (1991). Baydack et al. (1999) describe an approach to analyze species viability 

by using historic vegetation structure, composition, and function. We use this approach and compare 

changes in vegetation, structure, and function to historic availability along with population and habitat 

status and trend data. The Vegetation section (3.2) describes the historical vegetation patterns and 

structures on the Bitterroot NF. 

Note: unless otherwise stated, the analysis assumes that other ownerships do not contribute to the needs of 

the species.

3.8.5 AFFECTED ENVIRONMENT AND EFFECTS TO WILDLIFE

A. Old Growth Habitat

The direct effects analysis of old growth habitat in the Lower West Fork analysis area focuses on old 

growth habitat characteristics. The indirect effects analysis focuses on species associated with old growth 

habitat, such as marten and fisher, pileated woodpecker, and flammulated owl (Section 3.8.5 D, E, and K,

respectively). 

Analysis Method & Reference Conditions
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-3

Table 3.8- 1: Western Montana Zone Old Growth Type Characteristics (Green et al. 1992, errata 2005) 

Description Minimum Criteria Associated Characteristics Cover Type1 Habitat Type Group2 Minimum Age of Large Trees (years) Minimum Number of Live Trees/acre by DBH Minimum Live Tree Basal Area (sq ft/ac) DBH Variation3 Dead/Broken Top (%) range Probability of Downed Woody Material Decay (%) Range Canopy Layers (#)

Snags Range≥ 9”

1- PP, DF, L, 

GF LP A & B 170 8 ≥21” 60 M 123-23 L – M 50-11 Single 60-22

2 - DF, L, PP, 

SAF, GF C 170 8 ≥21” 80 H 110-21 M 52-12

Single/

Multiple

7

2-37

3 - LP C, D, E, 

F, G, H 140 10 ≥13” 60/70/80 L 115-22 H 62-15 Single 190-92

4 - SAF, DF, 

GF, C, L, 

MAF, PP, 

WP, WH, 

WSL

D, E, F 180 10 ≥21” 80 H 9

0-19 H 9

1-31

Single/

Multiple

15

2-43

5 - SAF, DF, 

GF, L, MAF, 

PP, WP, WSL

G, H 180 10 ≥17” 70/80 M 9

1-18 H 6

0-12 Multiple 12

3-36

1 PP: ponderosa pine, DF: Douglas- fir, L: western larch, GF: grand fir, LP: lodgepole pine, SAF: Engelmann spruce and 

subalpine fir, C: western redcedar, AF: .WP: western white pine, WH: western hemlock, WSL: combinations of alpine larch, 

whitebark pine, and limber pine, MAF: mountain hemlock, alpine larch, and subalpine fir 2 Habitat Type Groups: Habitat types grouped according to geographic zone, and grouped again by similarity of temperature 

and moisture regimes in each geographic zone (See Appendix A in Green et al. 2005) 

3 L: low, M: Moderate, H: high

The Forest Plan objective for old growth habitat management is to “maintain sufficient old growth habitat 

on suitable timberland to support viable populations of old growth-dependent wildlife species.” The Forest 

Plan definition of old growth habitat was documented as a resource standard: “stand conditions that qualify 

as old growth will vary by habitat type and landform.” The Forest Plan provides criteria to consider for 

identifying old growth habitat including: 

Ø large live trees, generally 15 trees per acre greater than 20 inches diameter breast height 

(dbh) for species other than lodgepole pine

Ø canopy closure at 75 percent of site potential

Ø stand structure usually uneven-aged or multistoried

Ø generally 1.5 snags per acre greater than six inches dbh and 0.5 snags per acre greater 

than 20 inches dbh

Ø more than 25 tons per acre of down material greater than six inches diameter 

Ø heart rot and broken tops in large trees are common 

Ø mosses and lichens are present 

The Forest Plan states standards for maintaining old growth habitat by Management Area. The Forest Plan 

specifies that patches of old growth habitat should be at least 40 acres and well distributed over the 

Management Areas. The timber stand is the unit of delineation for old growth habitat. If a stand of old 

growth is slightly less than 40 acres in size, it is still managed as old growth.

Green et al. (1992, errata 2005 p. 1) describe old growth forest types of the northern region and provide 

local definitions of old growth for use in Forest Plan implementation (Table 3.8-1). The document states 

that, “Where there are conflicts with existing plan requirements, differences will be worked out on a case-
Affected Environment & Environmental Consequences - Wildlife 

3.8-4 Lower West Fork Project Final EIS 

by-case basis.” Since the Forest Plan “provides criteria to consider,” there are no conflicts between Green

et al (1992, errata 2005) and Forest Plan standards. 

Old growth habitat was analyzed using inventories from 2001 to present as mapped and recorded in the 

TSMRS/FACTS database and the Bitterroot NF Wildlife Database. Over 1,400 acres were field evaluated. 

Old growth habitat was re-examined in 2008, both in and outside of potential treatment units.

Some people view individual large, old, live or dead trees as old growth. These trees are components of 

old growth habitat but are not the sole criterion that defines the habitat. Stand structure and characteristics

defined in the Forest Plan and scientific literature are the basis of the old growth habitat analysis. Large 

snags are important to wildlife and the project effects on snags are discussed in Section 3.8.5 B. Mature 

trees that are outside of designated old growth habitat are also important to various wildlife species. 

Project effects on mature stands, as they affect specific wildlife habitats, are discussed in Sections 3.8.5 D –

marten and fisher, E- pileated woodpecker, and K-flammulated owl. 

Old growth habitat inventories indicate there are approximately 4,265 acres of old growth habitat in the 

Lower West Fork analysis area, about 11 percent of the analysis area (Fig. 3.8-1). We estimate the 2007 

Rombo Fire burned about 1,423 acres of old growth habitat based on an analysis of fire severity using 

RAVG and preliminary findings in a study on the Lolo NF (USDA 2008). The large live tree and down 

woody debris components were the most notable old growth habitat characteristics destroyed. According 

to preliminary findings on the Lolo National Forest, only one of 11 study stands retained its value as old 

growth forest habitat following a fire (USDA 2008). One hundred percent of the stands that burned with 

high or mixed intensity and 83 percent of the stands that burned with low intensity lost their old growth 

characteristics. Ninety-one percent of the old growth stands burned by wildfires lost their old growth 

characteristics through a combination of direct fire mortality, delayed fire mortality, and mortality caused 

by post-fire agents such as bark beetles (USDA 2008). Monitoring following the fires in 2000 indicate that 

50 percent of the old growth burned at moderate to high severity because of the high fuel loads and stand 

density resulting from fire suppression (USDA 2000d). Based on this information, most of the old growth 

stands affected by the Rombo fire no longer meet the requirements for old growth habitat. In the Lower 

West Fork analysis area, approximately 1,423 acres of suitable old growth habitat was burned in the 

Rombo fire.

Affected Environment

Currently, Forest Plan Standards for old growth habitat distribution in management area 1 (MA1) are being 

met in five of 19 3rd order drainages. Standards are met in two and three of the 19 3rd order drainages in 

MA 2 and MA 3a, respectively (Table 3.8-2). The 3rd order drainages include areas outside of the Lower 

West Fork analysis area. 

Most of the old growth habitat in the analysis area is in warm, dry habitat types, habitat type groups A and 

B (Table 3.8-1; See also Vegetation Section 3.2 for habitat type group descriptions). The Vegetation 

section shows a decline in mature to over-mature ponderosa pine and increasing density of mature to overmature Douglas-fir in the Lower West Fork analysis area relative to historic reference conditions. 

Fire suppression has modified old growth habitat on warm, dry habitat types in much of the Lower West 

Fork analysis area. Fire suppression has successfully excluded low intensity fire and extended the fire-free

interval. The most notable changes have occurred on the moister end of habitat type groups A and B, the 

dry Douglas-fir habitat types. In the Lower West Fork analysis area, the Douglas-fir stand component is 

increasing as stand density increases, and there is less ponderosa pine regeneration. Current threats to this 

ecosystem component are three fold: 

Ø There is a trend away from the desired condition as stand composition shifts dominance 

from ponderosa pine to Douglas-fir. 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-5

Figure 3.8- 1: Old Growth Habitat in the Lower West Fork Area (2001 to Present)
Affected Environment & Environmental Consequences - Wildlife 

3.8-6 Lower West Fork Project Final EIS 

Table 3.8- 2: Percentage of Old Growth Habitat on Suitable Land by 

Management Area and Drainage 

3rd Order Drainage

Old growth by Management Area (%)

(Forest Plan Standard in parenthesis) 

MA 1

(3%)

MA 2

(8%)

MA 3a

(8%)

01a453-2 31 NA2 NA

02e424-1 NA 1 5

02e424-2 0 0 9

02e425-1 NA 0 11

02e427-4 0 6 7

02f427-3 NA 0 0

02g449-1 NA 0 63

02h449-1 0 9 0

02h449-2 0 9 NA

02h449-3 0 0 NA

02h449-4 4 0 NA

02h450-1 6 3 NA

02h450-2 0 2 NA

02h450-3 0 0 NA

02h451-1 20 0 NA

02h451-2 11 5 NA

02h451-3 18 1 NA

02h451-4 0 NA NA

02i450-1 NA 2 6

02i452-1 0 1 1 1 Bold number indicates MA by third order drainage meets or exceeds Forest Plan Standards 2 NA: MA does not exist in this drainage.

Ø The risk of losing old growth habitat increases as competition for moisture intensifies and 

increases the susceptibility of the old-growth component to insects and disease (Sala and 

Callaway 2004).

Ø There is a high potential of severe fire because of the high fuel loads, stand density, and 

ladder fuels. If a fire occurred, the high fuel loads and ladder fuels would carry fire 

through the crowns and return the old growth or mature stands to an early seral stage. 

Stand-replacement forest fires usually alter the animal community more dramatically than 

understory fires (Smith 2000).

Wildlife associated with old growth habitats are adapted to survive the frequency, season, size, intensity, 

and uniformity that characterizes fire in that habitat. Substantial changes in these characteristics change the 

habitat utility and many old-growth associate species decline (Smith 2000).

Pileated woodpeckers, an old growth management indicator species, and flammulated owls, a sensitive 

species, live primarily in habitat type groups A and B. High frequency, low or mixed intensity fire is 

characteristic of these habitats (Bull and Jackson 1995). The old growth stand structure produced by low 

intensity fires was a relatively open forest stand of predominantly large ponderosa pine trees, a few large 

snags, and large down logs. The large snags provide nesting, roosting, and feeding habitat and the large 

down logs provide feeding habitat.
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-7

Alternative 2 ~ Potential Impacts on Old 

Growth

Old growth characteristics retained after 

treatment

Fuels reduced on 260 acres of old growth in 

warm, dry habitat types

Reduction of snags and woody debris though 

levels retained within historic range

Alternative 1 ~ Potential Effect on Old Growth

No direct affect on existing old growth habitat 

If high intensity fire occurs:

Risk of additional loss of old growth habitat

Pine marten, and other old growth associated species, primarily occupy the higher elevation habitat type 

groups (C, G, E, F, and H). Their typical habitat is high density, mature or old stands with abundant down 

woody material, which provides subnivean habitat, habitat that is in or under the snow layer (Douglas and 

Strickland 1987). 

Alternative 1

Direct and Indirect Effects

The No Action alternative would not change the amount 

of existing old growth habitat or conditions within the 

analysis area. This alternative would not encourage 

progression of existing immature stands towards old 

growth conditions because it would not reduce the high 

stocking densities present in many of these stands. The 

risk of losing ponderosa pine old growth habitat would 

increase because encroachments of grand fir and 

Douglas-fir in the understory would continue. These smaller, shade tolerant trees compete with the older 

trees for water, which increases stress on the older trees and makes them vulnerable to attack by insects and 

pathogens. In addition, the dense understories increase the vulnerability of the old growth ponderosa pine 

to fire by acting as ladder fuels that carry fire into the crowns of the larger trees. 

This alternative would not reduce the risk of high intensity fire because it would not reduce fuel loads in the 

analysis area. It would not improve tree vigor because it would not reduce stand densities. Trees would be 

susceptible to insects and disease and fuels would continue to increase. Likewise, the probability of high 

intensity fire would increase. Moderate to severe fires would likely convert old growth stands to early seral 

development stages (USDA 2008). 

Alternative 2

Under Alternative 2, we would treat fuels on approximately 260 acres (6%) of old growth habitat using 

prescribed fire in units 4, 8, 9, 15, 33, 60A, 61A, 70, and 71. Fuels would be treated before ignition by 

commercial and non-commercial thinning (slashing). Commercial thinning followed by prescribed fire 

would occur on 55 acres (1%) and prescribed fire with understory fuels slashing would occur on 205 acres

(5%). Fuels need to be reduced before burning to control the fire intensity.

In Alternative 2, there would be no change to existing old growth habitat percentages or conditions because 

the proposed treatments would be designed to meet the definitions of Green et al (1992). The treatments 

would reduce fuels and retain old growth stand 

characteristics typical of the habitat types. These 

treatments would preserve these habitats and the valuable 

habitat components required by many bird and small 

mammal species. 

The Forest Plan states that long rotations will be prescribed 

to meet old-growth requirements on suitable timberland in 

Management Areas 1, 2, 3a, 3b, and 3c. It also states that 

old-growth stands may be logged and regenerated when 

other stands have achieved old-growth status (USDA 1987:

p. II-20). These requirements would be met through 

implementation of Alternative 2. Old growth habitat 

characteristics, where they exist before treatment, will be retained after treatment. Mitigations (FEIS 

pg. 2-23) to maintain old growth habitat characteristics following treatment include:
Affected Environment & Environmental Consequences - Wildlife 

3.8-8 Lower West Fork Project Final EIS 

Ø The number of live trees over 21 inches, an important old growth habitat characteristic 

and a minimum criteria in Green et al.(Table 3.8-1), will generally not change. Outside 

of the old growth portion of those units, incidental large green trees may be harvested. 

Ø The number of large dead trees removed would be incidental for operational safety or 

silvicultural prescription objectives. 

Ø Low intensity, surface fires would be prescribed to reduce fuel loads and prevent the loss 

of the large live tree component below the minimum old growth habitat characteristics 

(Table 3.8-1).

Ø Fuels, concentrated near the bases of larger trees or in excess of that needed to maintain a 

surface fire, would be piled and burned or otherwise treated to prevent damage to the 

large tree component. 

Ø Where deemed necessary by a Silviculturist or Wildlife Biologist, ponderosa pine would

be protected from bole and crown scorch to prevent mortality.

Snags would be retained unless they present on OSHA defined hazard. Snags are characteristic of old 

growth habitat and not a minimum criterion in the Green et al. study. Because the stands in the Lower 

West Fork analysis area are predominantly green stands, there may not be many snags. No snags would be 

harvested in old growth areas unless they are a safety hazard as defined by OSHA (29CFR 110.266(h)(1)(v, 

vii). In areas with low snag density, the residual live tree component would provide recruitment snags over 

time.

Downed woody debris would be retained as described in the downed woody debris standard (Section 

1.7 D and 2.3). For habitat type groups A and B, 5-10 tons/acre of downed woody debris would be 

retained (FEIS Section 1.4.1 and pg. 2-23). This level of coarse woody debris is less than the 25 tons per 

acre recommended for old growth habitat in the Forest Plan. However, current research indicates there 

would be low (<20%) to moderate (21-40%) probability of abundant large down woody material in warm,

dry habitats and moderately warm, dry habitat types (Graham et al. 1994, Green et al. 1992, errata 2005, p. 

23; Table 3.8-1). The recommendation of 5 and 10 tons per acre of downed woody debris is consistent 

with old growth habitat characteristics in these habitat type groups. Green states, “The probability of 

rotten, down log pieces greater than 9 inches diameter is low to moderate in this old growth type. Average 

litter and duff depth is less than 2 inches” 

Stand prescriptions by a certified silviculturist, fuels specialist, and wildlife biologist will assure treatments

retain old growth habitat characteristics. This interdisciplinary, site specific prescription would retain a 

minimum live basal area of 60 ft2

/acre, and retain the other minimum criteria identified in Green et al. 

(1999 errata 2005) (Table 3.8-1). Both snags and woody debris would be irregularly distributed in clumps. 

The Silviculturist or Wildlife Biologist would monitor the treatments to ensure objectives are met. The old 

growth characteristics and ecological functions would be retained in old growth treatment units by 

decreasing stand density, thinning from below, and retaining large ponderosa pine, snags, and down woody 

debris. Implementation of this alternative would not affect the amount of old growth habitat in the Lower 

West Fork analysis area.

Mitigation and monitoring measures stated above would retain old growth characteristics, and ecological 

function in old growth stands. A regional research project studying the interactions among bark beetles, 

pathogens, and conifers in North American forests found, “Tree-density management through thinning is 

one management alternative that could reduce mortality caused by Dendroctonus spp. [bark beetle] in oldgrowth ponderosa pine and Douglas-fir, and simultaneously retain old-growth characteristics” (PF-WL001, pg. 19). Quesnel (2002, p. iii) found that old growth stands treated to retain basal areas similar to 

those retained under Alternative 2 maintained their wildlife values four years after treatments. 

Additionally, a stand with old growth structure and large amounts of tree mortality was treated to accelerate 

regeneration and reduce fuel loads in Oregon, while maintaining its function as old growth. They found 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-9

Alternative 3~ Potential Impacts on Old Growth

Old growth characteristics retained after treatment

Fuels reduced on 228 acres in old growth in warm 

dry habitat types

Reduction of woody debris though levels retained 

within historic range

Mitigations reduce risk of unintentional loss during 

prescribed burning.

If high intensity fire occurs:

Risk some loss of old growth habitat on the east side 

of the West Fork River

that the old growth stand continued to look and function as old growth for the species they monitored (Bull 

1995, pg.11). 

Reintroducing fire to these old growth stands would prepare a mineral seedbed favorable for ponderosa 

pine regeneration, as appropriate for the habitat type, and could increase stem growth of remaining trees. 

Prescribed fire can cause mortality in ponderosa pine and Douglas-fir by scorching crowns, boles, and 

buds. Low intensity fire would be prescribed for the low elevation, ponderosa pine units to prevent 

mortality in the larger ponderosa pine. Prescriptions would be written to avoid large tree mortality in the 

old growth stands. 

Prescribed fire may increase tree stress, which would increase tree susceptibility to insects and disease. 

Prescribed burning may unintentionally kill or stress approximately 15 percent of the large trees. Excess 

fuels or fuels that have accumulated at the bases of trees designated for retention would be piled and burned 

prior to the underburn. Prescribed fire has been a successfully used tool on the Bitterroot NF since 1952.

Commercial Treatments – These treatments occur predominantly in Douglas-fir/ponderosa pine and 

Douglas-fir habitats, habitat type groups A and B. A substantial decrease in the ponderosa pine component 

from historic conditions characterizes these units and they are vulnerable to continued losses. Commercial 

thins would leave approximately 60 – 100 ft2 of basal area/acre in ponderosa pine and Douglas-fir, and to a 

lesser extent lodgepole pine. This basal area is at or above the minimum basal area criteria for old growth 

in habitat type groups A and B as described in Green et al. (1994, errata 2005; Table 3.6-1). Treating these 

stands would reduce competition for growing space, nutrients, and water. The largest, healthiest, and 

dominant ponderosa pine would be retained in the stand. Density reductions would remove some 

competing overstory trees and thin from below. Increasing the growing space would increase the resistance 

of the trees to insect, disease, and fire. These treatments improve the probability that old growth habitats

would remain on the landscape. 

Non-Commercial Treatments (Slashing) and Prescribed Fire –

In summary, the commercial, non-commercial, and prescribed fire treatments in Alternative 2 would 

improve the resilience of old growth stands and the probability they would remain on the landscape 

following a fire. Old growth habitat characteristics would be retained following treatment and the 

reduction in fuel loads and stand density would 

decrease potential fire behavior in the event of a 

fire.

The non-commercial (slashing) fuel 

treatment would cut the small diameter, understory trees. Depending on the fuel load, the slash would be 

piled and burned or lopped, scattered, and underburned. The prescribed fires would remove the excess 

fuels on these sites, which would reduce the potential of a ground fire transitioning to a crown fire. The 

large tree components, live or dead ponderosa pine, and to a lesser extent Douglas-fir, would be retained. 

By mimicking the natural fire regime and reintroducing fire as a disturbance factor, stands may progress 

towards structures and species compositions characteristic of these habitat types. 

Alternative 3

Under Alternative 3, 228 acres (5%) of old growth 

would receive the same treatments and 

mitigations as in Alternative 2 on the west side of 

the West Fork River. Therefore, the effects on the 

west side of the River would be the same as in 

Alternative 2. 

No old growth units would be treated on the east 

side of the River under Alternative 3. Thus, about 

29 acres of old growth in unit 15 and 3 acres in 

unit 71 would not be treated. The terrace stands 
Affected Environment & Environmental Consequences - Wildlife 

3.8-10 Lower West Fork Project Final EIS 

adjacent to Unit 15 would be treated, which would decrease fire behavior adjacent to the old growth unit. 

Commercial Treatments – The effects of commercial thinning would be the same as in Alternative 2. The 

only difference would be that 29 acres of old growth would not be treated on the east side of West Fork 

River. This stand would remain vulnerable to fire in the event of an ignition. However, treatment of the 

adjacent terrace units and fuel reductions from the Rombo fire would lower fire behavior and may buffer 

fire intensity in the unit (Fig. 3.3-8). 

Non-Commercial Treatments (Slashing) and Prescribed Fire – The effects of slashing and prescribed fire 

would be the same as those in Alternative 2 on the west side of the West Fork River because the treatments 

would be the same. Unit 15 is the only old growth stand on the east side of the river that would not be

treated. The risk of losing this old growth unit in the event of a fire would remain high but it is buffered on 

three sides by treated terrace units or areas where the Rombo fire reduced fuels. 

Geographic Boundaries and Time Period

Cumulative Effects

The defined effects area for old growth is the 19 3rd order drainages, which are entirely or predominantly 

inside the Lower West Fork analysis area (Figure 3.8-1). This analysis area is appropriate to analyze 

incremental effects from project activities in conjunction with past, present, and reasonably foreseeable 

actions. 

Alternatives 2 & 3 

The reduction in fuels (green and dead) would last approximately 25 – 50 years until a new understory 

developed and downed woody debris accumulated. Future fire disturbance or vegetation management 

could extend the duration of low fuel loads.

Individual large trees may be cut or burned in the course of unit treatments. There would be no effect on 

old growth stand status from the incidental loss of large trees because old growth stand criteria defined by 

Green et al. (1992, errata 2005) and specific to the habitat type would be retained. The effect of losing an 

incidental large tree would continue until a new tree regenerates and grows to maturity (approximately 100 

years).

Individual snags may be felled but the remaining snag density would meet the criteria in Green et al. (1992, 

errata 2005). Though individual snags may be cut, they would still contribute to old growth stand 

characteristics as large, coarse woody debris. The snag loss would remain an effect until a mature or old 

tree dies.

Green et al. (1992, 2005 errata, pg. 2) noted the bulk of pre-settlement old growth in the northern Rockies 

was in the lower elevation, ground-fire maintained ponderosa pine/western larch/Douglas-fir habitats,

based on historic data. Lesica (1996, pg. 37) estimated that 20 – 50 percent of low and many mid-elevation 

forests were in old growth condition. Fire suppression for the last 50 years has left these forest 

communities with different vegetation compositions, structures, and fuel accumulations than were

historically present (Fisher and Bradley 1987). Much of the area is dominated by dense, multi-storied 

structures with a high composition of Douglas-fir. Lesica states (1996, pg. 37), “By reducing the 

occurrence of low intensity burns, fire suppression has increased the chance of stand-replacing fires in 

many remaining old growth stands.” Alternative 2 and to a lesser degree Alternative 3 would reduce fuels 

and reintroduce fire, which would similarly reduce the risk of stand replacing fires in old growth.

Other Actions

Timber harvest in the 1960s, 1970s and 1980s on the warm, dry habitats contributed to the reduction of old 

growth habitat (See Cumulative Effects in Section 3.2 - Vegetation Figs. 3.2-3 and 3.2-4). Most of the 

harvest occurred in the 1980s. Timber sales were typically clearcuts with machine site preparation and few 

live trees, snags or woody debris were left in the units. We do not know what percentage, if any, of those 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-11

stands were old growth habitat. Nor do we know if those areas had not been harvested, whether the stands 

would provide old growth habitat today. Though we do not know how much old growth habitat was 

previously logged, we can assume that some old growth habitat has been lost.

The old growth component cannot meet many of the Forest Plan standards for old growth habitat 

distribution in this area until a green forest canopy regenerates. Under Alternative 1, the probability of high 

intensity fire burning old growth would increase as fuel loads increased from competition and tree 

susceptibility to insect and disease mortality. The probability of high intensity fires burning old growth 

would be similar in Alternatives 2 and 3 because the treatments are the same on the west side of the West 

Fork River and only one old growth stands on the east side of the River would be treated in Alternative 2 

and not treated in Alternative 3. The terrace units treated on the east side of the River and the area burned 

during the Rombo fire may buffer some of the remaining old growth from high intensity fire. Alternative 2 

and 3 would potentially make stands on the west side of the West Fork River more resilient to insects, 

disease, and fire. 

The management practice of clearcutting large areas of mature stands spanned the late 1960s and 1980s, 

and ended in the early 1990s. The current trend of increasing stand density and stand composition that 

favors climax species would continue under fire suppression on old growth in warm dry habitat types. 

Today, however, there is broad consensus that active management through thinning and prescribed fire is 

needed in many forests (Brown et al. 2004, pg. 1). Actions proposed in Alternatives 2 and 3 would reverse

the negative trends of fire suppression and restore historic composition and structure. The more open 

stands of fire-resistant, seral tree species would allow for the use of fire to maintain stand conditions and 

create more sustainable stands.

Trends & Broader Context

Across the Bitterroot NF on lands suitable for timber production (MA 1, 2, 3a, 3c) there is approximately 

18 percent old growth habitat, based on the 2004 Forest old growth inventory. This percentage ranges 

across management areas as follows: MA 1 – 20%; MA 2 – 14%; MA 3a – 17%; and MA 3c – 23% (PFWL-003).

B. Snags

The effects analysis of snag habitat in the Lower West Fork analysis area focuses on the availability of the 

habitat across the analysis area, and in specific treatment units. The effects of implementing this alternative 

on some species associated or dependent on snag habitat occurs in Sections 3.8.5 D – marten and fisher, E 

– pileated woodpecker, K – flammulated owl, and L – black-backed woodpecker. 

Effects Analysis Method & Reference Conditions

We reviewed the scientific literature applicable to snags in the northern Rocky Mountains to determine an 

appropriate number required to maintain wildlife habitat while meeting the fuel reduction objectives in the 

Lower West Fork Project area. This review included the Northern Region Protocol for Snag Management 

(USDA 2000), Abundance and Characteristics of Snags in Western Montana Forests (Harris 1999), OldGrowth Forest Types of the Northern Region (Green et al. 2005), and the Interior Columbia Basin 

Ecosystem Management Project FEIS (USDA 2000, Appendix 12, p. 12-4). Table 3.8-3 summarizes the 

range of snags in the various habitat type groups and the minimum range proposed for this project.

The Rombo Fire burned approximately 11,600 acres in the southeastern portion of the Lower West Fork 

analysis area. It is the second largest fire within the project area since 2000. The fires in 2000 burned in 

the eastern portion of the analysis area but the west side of the project area did not burn in either of the fire 

events.

Affected Environment
Affected Environment & Environmental Consequences - Wildlife 

3.8-12 Lower West Fork Project Final EIS 

Alternative 1 ~ Potential Impacts on Snags

No significant effect on snag density 

Snag numbers would continue the current 

trend of increasing where insect and 

disease mortality occur and in recent 

burns.

If high intensity fire occurs:

Loss of some existing snags and downed 

 

Table 3.8- 3: Snags per Acre by Habitat Type as Cited in the Literature

1 Habitat type groups are described in Table 3.8-1.

There is an abundance of snags on the Bitterroot NF. The fires in 2000created snags on almost all 307,000 

acres of burned forest. About 46 percent of the fires burned with moderate or high intensity, which killed 

most of the trees and turned them into snags. Low intensity fire on 54 percent of the area killed up to 40 

percent of the trees, either individually or in small groups. The Lower West Fork project is on the edge of 

the Douglas-fir bark beetle epidemic that recently affected the southern half of the Forest, mainly on the 

Sula Ranger District. Though not at epidemic levels, the Douglas-fir bark beetle has created pockets of 

snags where larger Douglas-fir comprise a high percentage of the trees. Douglas-fir dwarf mistletoe 

infection is prevalent in some areas and contributes to snag recruitment. Fir engraver beetle, western pine 

beetle and other insects and disease are present at endemic levels and continue to create small pockets of 

snags scattered across the landscape. Large ponderosa pine snags are relatively uncommon at lower 

elevations in the western portion of the analysis area but are more common on the eastern portion of the 

project area due to the fires in 2000 and 2007. 

In the Lower West Fork analysis area, the composition of ponderosa pine in habitat type groups A & B is 

less than would be expected historically because of past timber harvest activities. As a result, fewer 

ponderosa snags are available than would be expected historically. All snags in the Lower West Fork 

treatment units would be retained, unless they present an OSHA defined hazard. 

Alternative 1

Direct and Indirect Effects

This alternative would not reduce the number of existing 

snags within the analysis area because no stands would 

be harvested or burned. In the short term, snag numbers 

would slowly increase in the western portion of the 

analysis area as trees die from endemic levels of insect 

and disease activity. Some existing snags would fall 

from decay progression in their roots and butts, strong 

winds, and snow loads. Snags near open roads would be 

vulnerable to firewood cutting. Overall, the number and 

distribution of snags would probably not change from 

the existing condition. In the long term, the existing 

dense canopies and high fuel loads that are common 

throughout the analysis area would continue to increase 

Literature Habitat Type A1 Habitat Type B Habitat Type C Habitat Type 

E, F, & H

Harris ≈2.92 ≈6.66 ≈9.45 ≈14.58 to 17.47

Green et al.

0 to 22 with an 

average of 6 trees> 

9”dbh

0 to 22 with an 

average of 6 trees > 

9”dbh

2 to 37 with an 

average of 7 trees > 

9”dbh

0 to 92 with an average 

of 15 trees > 9”dbh

ICBEMP FEIS

Butte RAC

Snags >21”

0.4 – 3.4 0.4 – 3.4 0.4 – 3.4 3.0 – 6.9

USDA 2000 1 to 2 4 6 to 12 6 to 12

Lower West Fork 

Minimum Snag 

Requirements

2 to 5

Habitat Type Group 

A & B

2 to 5

Habitat Type Group 

A & B

4 to 12

Habitat Type Group 

C & G

10 to 15

Habitat Type Group 

E, F, & H
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-13

the risk of a large, intense fire that could kill most or all of the trees over a large portion of the analysis 

area. If such a fire occurred, it would dramatically increase the number of snags within the burned area. A 

large concentration of snags would provide abundant habitat for snag associated/dependant wildlife species. 

Alternatives 2 and 3

In the Lower West Fork Project area, we do not propose silvicultural or fuels treatments that would harvest 

snags, except on an incidental basis where snags present an OSHA defined safety hazard (29CFR 

110.266(h)(1)(v, vii). Therefore, this project complies with the Forest Plan snag standards (USDA Forest 

Service 1987, pg. II-20). In the short term, snag numbers would gradually increase in the western portion 

of the analysis area as trees die from endemic levels of insect and disease activity. Some existing snags 

would fall from decay progression in their roots and butts, strong winds, and snow loads. Snags near open 

roads would be vulnerable to firewood cutting. Overall, the number and distribution of snags would not 

change from the existing condition. 

In the long term, the proposed treatments would decrease the potential loss of snags and snag recruitment. 

The proposed reductions in stand density and fuel loads would decrease the risk of large, intense fire that 

could kill most or all of the trees over a large portion of the analysis area. This reduced risk would allow 

for the natural variation of snags that more closely resembles historic conditions while providing adequate 

habitat for snag associated/dependant wildlife species.

Cumulative Effects

The Lower West Fork analysis area is the cumulative effects analysis area for snags. This is the 

appropriate area to analyze the incremental effects of the project activities on snags in conjunction with 

past, present, and reasonably foreseeable actions. An assessment of information available at the Forest 

level provides additional context. 

Geographic Boundaries and Time Period

Approximately 10,800 acres of past harvest have occurred within the Lower West Fork analysis area since 

1953. Of this harvest, few to no snags were left on about 8,700 acres. Since 1987, snag levels have been 

managed to retain snags that do not present safety hazards within treatment units (Forest Plan pg. II-20). 

There is approximately 33,000 acres (87%) of the Lower West Fork analysis area that has not been 

harvested and snags remain on the landscape. 

Other Actions

None of the Forest Service ongoing or future activities listed in Appendix B would have measurable effects

on snag habitat because Forest Plan snag retention guidelines would be met. 

Snags currently may be more abundant and widely distributed across the Bitterroot NF than in any other

time. The 2000 fires burned about 307,000 acres of National Forest and created snags across most of the 

burned area. Salvage harvest occurred on about 10,000 acres of the burned area. In the salvage harvest 

units, the number of snags retained approximated the number that occurred historically in unburned forests. 

Monitoring shows that snag guidelines were consistently met (PF-WL-006). 

Trends and Broader Context

Snags are abundant and well distributed on 330,000 acres of the Selway-Bitterroot Wilderness and SelwayBitterroot and Allan Mountain Roadless Areas, from the fires in2000 and subsequent fires, and across the 

rest of the National Forest that is not in the suitable land base for timber harvest. With the abundance of 

snags available from recent fires, snag retention, and reduced probability of high fire intensity from this 

project, there would be no cumulative reduction of snag habitat from future projects. Sufficient snag 

habitat is available to retain snag dependent species viability on the Forest (Sections: 3.8.5 D – marten and 

fisher, E – pileated woodpecker, K – flammulated owl, and L – black-backed woodpecker). The proposed 

harvest in this project would have no effect on snags or no cumulative effect with past, present, or 
Affected Environment & Environmental Consequences - Wildlife 

3.8-14 Lower West Fork Project Final EIS 

foreseeable projects. Snag types and densities would provide sufficient snag habitat for snag associated or 

dependent species. 

C. Elk (Cervus elaphus) (Management Indicator Species) 

Four evaluation criteria were used to predict project effects on elk for each alternative: 

Effects Analysis Method & Reference Conditions

Ø Population

Ø Habitat including thermal cover

Ø Habitat effectiveness

Ø Security

Population

Affected Environment

In 1987, the elk population in the Bitterroot Valley was estimated at 3,537 elk. This estimate is the 

benchmark for meeting Forest Plan Desired Conditions (Forest Plan pg. II-14) and is the baseline for 

comparing effects in this analysis. The elk population has steadily increased in the Valley since the 1960s 

and peaked in 2005 with 8,169 elk. The population has declined since, although the population has stayed 

well above the 1987 estimate (Table 3.8-4). 

Table 3.8- 4: Elk Populations Trends in the Bitterroot Valley and Hunting District (HD) 250. The Lower 

West Fork Analysis Area Makes Up About Eight Percent of HD 250.

Montana Fish, Wildlife, and Parks (MTFWP) sets elk population objectives, plus or minus 20 percent, for 

each hunting district and an overall objective for the Bitterroot Valley. Hunting districts (HD) 204, 240, 

250, 261, and 270 comprise the Bitterroot Valley. The population objective for the Bitterroot Valley is 

7070 elk, ranging between 5,656 and 8,484 elk. The Lower West Fork analysis area lies within and makes 

up eight percent of HD 250. HD 250 has an elk population objective of 2000 elk, ranging between 1,600 

and 2,400 elk. The 2009 spring survey counted 747 elk in HD 250, which is 63% below the objective. The 

2010 spring survey showed a slight increase in elk counted in the Bitterroot Valley and in HD 250. The 

population in HD 250 has shown a decrease in population for the past 5 years and has not met the 

population objective since 2005.

Prior to the 2007 hunting season, MTFWP liberalized hunting regulations and allowed a quota cow elk 

harvest in HD 250 to reduce the population and meet the State objective. During the 2007, 2008, and 2009 

hunting seasons the state reduced the cow harvest quota in order to stabilize the herd at objective. Hamlin 

and Cunningham (2009) deduced that the decline in population is most likely due to increased antlerless 

harvests and found no evidence that wolves or combined predator numbers have much to do with the 

decline in elk counted through 2008.

Habitat Including Thermal Cover

Thermal cover is a feature of elk habitat related to vegetative structure and lessens the effects of weather on 

elk (Toweill and Thomas 2002). To provide thermal cover, forested stands should be coniferous with 

average tree heights of 40 feet and canopy closure greater than 70 percent (USDA Forest Service 1978). 

The Bitterroot Forest Plan Record of Decision (USDA Forest Service 1987) requires 25 percent of winter 

range area to meet thermal cover requirements. A Forest Plan amendment is needed to treat stands that 

qualify as thermal cover. In commercial thin units, crown canopy would be reduced about 25 percent, 

which would more closely approximate the historic stand structure and composition for the habitat types. 

Elk Count 2005 2006 2007 2008 2009 2010

Bitterroot Valley 8,169 7,915 7,197 5,950 6,166 6,293

HD 250 1,914 1,462 1,373 863 747 764
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-15

Currently, there are 17,520 acres of winter range in the Lower West Fork analysis area. Thermal cover 

occurs on 3,680 acres (21%) of winter range. The fires in 2000 and 2007 burned 5,590 acres of thermal 

cover, 4,286 of those acres on winter range. The fires burned over 50% of the thermal cover on winter 

range and reduced thermal cover on winter range from 34 percent to 21 percent. However, as a response to 

the increased availability of water, nutrients, and light following the fires, the decrease in thermal cover 

initiated an increase in forage productivity. The newly available forage most likely offset the reduction of 

thermal cover (Lehmkuhl et al. 2002, Poole and Mowat 2005).

Recent research questions the necessity of thermal cover for wintering elk survival (Cook et al. 1998). 

Cook and others (1998) found “no significant, positive effect of thermal cover on condition of elk during 

any of the six experiments. In contrast, they found that dense cover provided a costly energetic 

environment, resulting in significantly greater over-winter mass loss, fat catabolism, and (in one winter) 

mortality.” Thus, thermal cover does not appear to be the determining factor for individual elk survival or 

elk population viability.

Habitat Effectiveness

The Forest Plan specifies elk habitat effectiveness (EHE) standards for roaded and unroaded 3rd order 

drainages based on the EHE model described by Lyon (1983) (Forest Plan pg. II-21). For roaded 

drainages, the standard is 50 percent EHE, or about 2 miles of open road per square mile (mi/mi2

). This 

Forest Plan standard helps achieve the objective of cooperating with the state of Montana to maintain the 

current level of big game hunting opportunities (Forest Plan pg. II-21). EHE was calculated based on 

assumptions in Lyon (1983), such as an open road is a road open to full-sized vehicles during all or part of 

the year, using only unpaved roads, and elk habitat is 100 percent effective when it is more than one mile 

from a road. Roads that are closed to full-sized vehicle use all year are counted as closed roads and roads 

that are closed seasonally are considered open roads for the purposes of this EHE analysis. However, 

effective road closures mitigate the effects of roads on EHE (Lyon 1983).

The EHE model described by Lyon (1983) was the best information available at the time the Forest Plan 

was implemented. Small elk herds are present within the roaded part of many Forest drainages throughout

the year and never migrate to higher elevation summer ranges. Vehicle traffic on those roads would reduce 

the effectiveness of elk habitat during some months of the year.

Six of the nineteen 3rd order drainages in the Lower West Fork analysis area do not meet the EHE standard 

(Table 3.8-5) because EHE is less than 50 percent (Fig. 3.8-2). In order to meet the EHE standard in four

of these drainages, the roads open to major trailheads would have to be closed. For example:

Ø 02h449-1 (East Piquett) NFSR 731 accesses Shook Mtn. Trailhead (Trail # 601)

Ø 02i450-1 (Violet Creek) 720 accesses Rombo Ridge Trailhead (Trail # 676)

Ø 02e424-1 (Lavene Creek) 5630A accesses Trapper Peak Trailhead (Trail #133)

Ø 02e424-2 (Baker Creek) NFSR5634 accesses Baker lake Trailhead (Trail # 234)

In 02f427-3 (Wheeler Creek) and 02h450-2 (East Main Piquett Creek) drainages, the upper end of the main 

roads would need to be closed to meet EHE standards. These roads access higher elevations and are used 

for forest management purposes. Because the open roads are in steep country and switchback across the 

slopes, the additional road miles are in habitat with low elk use and do not diminish elk security or increase 

elk vulnerability to disturbance. All other 3rd order drainages in the Lower West Fork Analysis Area meet 

EHE standards (Table 3.8-5).

Security

Subsequent to the EHE model, Hillis et al. (1991) developed a model to assess elk security during hunting 

season when elk are most vulnerable. The Bitterroot NF has used this model in project planning together 

with EHE to determine project effects on elk habitat.
Affected Environment & Environmental Consequences - Wildlife 

3.8-16 Lower West Fork Project Final EIS 

Alternative 1 ~ Potential Impacts to Elk

No impact to elk populations

No effect on thermal cover.

No effect on habitat effectiveness; remains below 

standards in 6 of the 19 third order drainages.

No change in security

If high intensity fire occurs:

a) Likely no significant effect to elk 

populations or viability

b) Further reduction of thermal cover

Table 3.8- 5: Open Road Density and Elk Habitat Effectiveness in the Lower West Fork Analysis Area

1

Shaded rows indicate drainages where EHE standards are being met.

Using criteria from Hillis et al. (1991), elk security areas are greater than 250 acres and more than one half 

mile from an open road. Security areas consist of both cover and openings, and reductions of cover do not 

necessarily jeopardize security. Adequate elk security exists when at least 30 percent of an elk herd unit 

qualifies as a security area (Hillis et al., 1991). Fifty-three percent of the Lower West Fork analysis area 

(20,400 acres) provides elk security habitat (Fig. 3.8-3). The fires in 2000 and the Rombo fire reduced 

cover within the security areas, but did not reduce security because no change in road management 

occurred. Additional road closures may extend the perimeter of existing elk security habitat but would not 

create any additional elk security areas. The terrain and manner in which the roads switchback across the 

slope prevent the creation of new security areas greater than 250 acres and one-half mile from an open 

road. 

Alternative 1

Direct and Indirect Effects

Alternative 1 would not change elk populations or elk 

vulnerability because no changes in habitat or road 

management would occur. 

Populations

Under the No Action alternative, 21 percent of the 

winter range in the Lower West Fork analysis area 

would provide thermal cover. In thermal cover created 

by fire exclusion, understory vegetation will continue 

to grow, increasing the amount of ladder fuels. The 

ladder fuels create a high risk of losing the overstory 

Thermal Cover

Watershed

Area Open Road Density 

(mi/mi2) Elk Habitat Effectiveness (%)

Acres Miles2 Alt 1 Alt 2 Alt 3 Forest Plan 

Standard Alt 1 Alt 2 Alt 3

02e424-1 (Lavene Creek ) 3,271 5.1 2.7 2.6 2.6 50 42 43 43

02e424-2 (Baker Creek ) 4,287 6.7 2.4 2.0 2.0 50 45 50 50

02e425-1 (Boulder Creek )

1 1,361 2.1 1.0 1.0 1.0 60 60 60 60

02e427-4 (Ward Creek ) 2,230 3.5 2.0 2.0 2.0 50 50 50 50

02f427-3 (Wheeler Creek ) 1,346 2.1 2.8 2.3 2.3 50 41 46 46

02g449-1 (Trapper) 717 1.1 0.0 0.0 0.0 60 100 100 100

02h449-1 (East Piquett) 1,184 1.8 2.6 2.6 2.6 50 43 43 43

02h449-2 (Upper East Piquett) 1,005 1.6 0.1 0.1 0.1 60 95 95 95

02h449-3 (Boundary) 1,534 2.4 0.0 0.0 0.0 60 100 100 100

02h449-4 (Lower East Piquett) 1,506 2.4 0.7 0.7 0.7 50 67 67 67

02h450-1 (West Main Piquett) 2,116 3.3 0.8 0.8 0.8 50 65 65 65

02h450-2 (East Main Piquett Creek) 2,220 3.5 2.6 2.6 2.6 50 43 43 43

02h450-3 (Britts Creek) 1,539 2.4 0.0 0.0 0.0 60 100 100 100

02h451-1(Upper West Piquett) 1,697 2.6 0.0 0.0 0.0 0.0 100 100 100

02h451-2 (Notch Creek) 1,833 2.9 0.0 0.0 0.0 60 100 100 100

02h451-3 (Castle Creek) 3,022 4.7 0.0 0.0 0.0 50 100 100 100

02h451-4 (Rombo) 2,675 4.2 0.0 0.0 0.0 60 100 100 100

02i450-1 (Violet Creek) 944 1.5 2.1 2.1 2.1 50 48 48 48

02i452-1 (Applebury Creek) 2,080 3.3 0.0 0.0 0.0 60 100 100 100
Affected Environment and Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-17

Figure 3.8- 2: Road Management and Elk Habitat Effectiveness in the Lower West Fork Analysis Area. 
Affected Environment and Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-19 

Figure 3.8- 3: Elk Security Habitat in the Lower West Fork Analysis Area. Fifty-three Percent of the Lower West Fork Analysis Area Provides Elk Security Habitat. 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-21

Alternative 2 ~ Potential Impacts to Elk

No impact on elk viability. Potential short-term 

displacement and increased vulnerability of

individuals.

Thermal cover reduced on approximately 1,072 acres to 

more closely approximate historic stand structure 

and composition. Forest Plan amendment required.

Elk habitat effectiveness improves slightly in three 3rd

order drainages. Five third order drainages remain

below Forest Plan standards. Forest Plan 

amendment required.

 

canopy due to crown fire and bole scorch as experienced in the fires during the last decade. 

No changes in road density or management would occur so EHE would remain below Forest Plan standards 

in six 3rd order drainages. The density of motorized routes would also remain high in ten drainages.

Habitat Effectiveness

Under the No Action alternative, no timber harvest or road building would occur so there would be no 

change from the current situation. The Lower West Fork analysis area meets elk security recommendations 

(Hillis et al. 1991).

Security

Alternative 2

Elk vulnerability would increase in the short term

because harvesting and prescribed fire would 

reduce tree density and elk may be easier to see. 

However, elk have adapted to use many 

assemblages of habitats given the situations they 

encounter as habitats change, and none of the 

prescriptions would have an impact on elk 

viability. 

Populations

Winter range thermal cover occurs in 19 units in 

habitat type groups A, B, C, and G. Twenty-two 

units (883 acres) in winter range contain thermal 

cover (Fig. 3.8-4). Prescribed fire and commercial thinning would affect four percent of the thermal cover

in winter range. Commercial thinning would have highest higher potential to reduce canopy closure than 

prescribed fire as burning would be kept at low to medium intensity. Thinning would open up more holes 

in the canopy and would therefore reduce more canopy closure. Commercial thinning would occur in 541 

acres of thermal cover. Thermal cover on winter range may be reduced to from 21 percent to 18 percent, 

and would be 7% below Forest Plan standards. The function of thermal cover is lost if canopy closure is 

reduced below 70 percent. The intent of project treatments is to maintain live canopy over time and canopy

remaining after harvest would continue to provide some thermal modification. Elk are habitat generalists, 

use a variety of habitats, and have varied diets. MTFWP concurred that the proposed standard for thermal 

cover in the Lower West Fork area should not affect the State’s ability to meet the elk population objectives 

(Forest Plan p. II-5) (Craig Jourdannais, pers. comm. 2008). 

Thermal Cover

Elk habitat effectiveness increases in Lavene Creek, Baker Creek, and Wheeler Creek drainages under 

Alternatives 2 and 3 but meets Forest Plan EHE standards only in Baker Creek drainage (Table 3.8-5). 

EHE cannot be met in East Piquett, Lavene Creek, and Violet Creek drainages because the main roads in 

these drainages are needed to access Shook Mountain, Trapper Peak, and Rombo Ridge trailheads, 

respectively. The size of the third order drainage and the terrain steepness affect meeting EHE standards. 

Lyon (1983) recommended against analyzing EHE on areas less than 3,000 acres. The smaller the 

drainage, the fewer road miles it takes to exceed EHE. In steeper terrain, more roads are needed to access 

the areas of interest. Though four 3rd order drainages do not meet EHE standards, 12 drainages exceed 60 

percent EHE. 

Habitat Effectiveness

Temporary roads and track line machine trails would be constructed in Lavene Creek, Baker Creek, 

Wheeler Creek, and Violet Creek drainages but the roads would be recontoured and seeded following use 
Affected Environment & Environmental Consequences - Wildlife 

3.8-22 Lower West Fork Project Final EIS 

Figure 3.8- 4: Thermal Cover and Proposed Treatment Units in the Lower West Fork Analysis Area
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-23

Alternative 3 ~ Potential Impacts to Elk

No impact to elk viability

Thermal cover is reduced to more closely 

approximate historic stand structure and 

composition. Forest Plan amendment required

Elk habitat effectiveness is the same as for 

Alternative 2. Forest Plan amendment 

required 

 

(FEIS pg. 2-18). However, these short road segments are not considered when calculating EHE (Lyons 

1983) and are unlikely to be used except by logging equipment. The temporary roads and track line 

machine trails would be recontoured following harvest so they would not be available for public use.

Fifty-three percent of the Lower West Fork provides elk security habitat. No activities under Alternative 2 

would change elk security habitat. No new permanent roads would be constructed and new temporary 

roads would not encroach in the security habitat. The roads proposed for storage and decommissioning are 

within the half-mile buffer created by the main access roads and would not increase elk security habitat 

(Fig. 3.8-2). 

Security

Alternative 2 proposes treatments that would reduce hiding cover. However, this reduction in cover is 

negligible and is designed to meet the natural range of variability for the desired future condition. No 

permanent road building is proposed; therefore, guidelines in Hillis et al. (1991) would be met. 

Alternative 3

The short-term effect on elk vulnerability would be slightly less in Alternative 3 than in Alternative 2 

because less timber harvest is proposed and more roads would be decommissioned or stored. The 

difference in effects between these alternatives is negligible and this alternative would not affect elk 

viability.

Populations

Suitable thermal cover would be reduced under 

Alternative 3 to the same extent as Alternative 2 on 

the west side of the West Fork River. Thermal cover 

would be maintained on the east side of the river 

because only terrace units would be thinned and these 

units generally do not qualify as thermal cover. 

Commercial thinning on approximately 241 acres 

may reduce thermal cover to 20 percent of the winter 

range (Fig. 3.8-4). The reduction of thermal cover 

would not affect elk population viability because the 

reduction in thermal cover would be very low and it 

does not appear to be as necessary to elk survival as 

once believed (Cook et al. 1998). 

Thermal Cover

No roads open to full-size vehicles were proposed for closure so open road density and EHE would remain 

the same as in Alternative 2 (Table 3.8-5). Though more road mileage would be decommissioned or stored 

than in Alternative 2, it would not improve EHE in 3rd order drainages: 02h449-1, 02h450-2, 02i450-1, or 

02f427-3.

Habitat Effectiveness

Effects of this alternative on elk security are the same as Alternative 2 because the main road system 

defines the elk security areas. 

Security

Geographic Boundaries 

Cumulative Effects

The elk cumulative effects analysis area is 19, 3rd order drainages, which are entirely or predominantly 

inside the Lower West Fork analysis area. This area is appropriate to analyze the incremental effects of 
Affected Environment & Environmental Consequences - Wildlife 

3.8-24 Lower West Fork Project Final EIS 

project activities on elk in conjunction with past, present, and reasonably foreseeable actions. An 

assessment of information available at the Forest level is considered to provide additional context. The 

cumulative effects of the site-specific Forest Plan Amendments for this project are also analyzed at the 

Forest level. 

Trends and Broader Context

The Montana Natural Heritage Program classifies elk as a G5 S5 species (PF-WL-025). This means that at

both the global and state scales, elk are considered to be common, widespread, and abundant, and not 

vulnerable in most of their range.

Elk Populations

The Lower West Fork analysis area is completely within and makes up eight percent of HD 250. Between 

1965 and 1983, spring elk counts averaged 497 elk. Spring counts have been declining since 2005 in this 

hunt district. The decline in the spring counts is thought to result from a combination of liberalized

antlerless hunting seasons, winter weather, changed elk movement patterns and a high predator population

(Craig Jourdannais, pers. comm. 2010). The MTFWP has implemented restrictive regulations until postseason counts exceed 1,120 elk for two consecutive seasons or counts exceed 1,400 elk and calf/100 cow 

ratios exceed 25 calves/100 cows for two consecutive years (Montana Statewide Elk Management Plan 

2004). The MTFWP also plans to fit elk with GPS collars to determine movement patterns (PF-WL-005). 

Housing development on winter range continues to be a management challenge causing the physical loss of 

winter range and limiting hunting access (Montana Statewide Elk Management Plan 2004). The Lower 

West Fork project would not create more open forage areas but would improve forage production under 

more open forest canopies (Youngblood et al. 2004).

No reasonably foreseeable projects would directly affect elk populations in the Lower West Fork analysis 

area or in HD 250. 

Thermal Cover

Historically, low intensity fires burned more area in habitat type groups A and B and impeded the 

development of thermal cover on elk winter range. Decades of fire suppression increased thermal cover, 

which decreased big game forage. Timber harvest, especially clearcut harvest, increased forage locally as 

it decreased thermal cover. The relatively small scale of the timber harvest together with fire exclusion 

allowed the development of more thermal cover than was typical in these habitat types. In the last decade, 

fires have reduced thermal cover on winter range by 54 percent in the Lower West Fork analysis area. 

There are no reasonably foreseeable actions in the analysis area that would further reduce thermal cover in 

the Lower West Fork analysis area. Outside of the analysis area, three percent of the winter range thermal 

cover would be treated in the Trapper-Bunkhouse project. Trapper-Bunkhouse treatments are expected to 

reduce winter range thermal cover to six percent. Though the Lower West Fork project maintains more 

thermal cover than that in Trapper-Bunkhouse (17% in Alternative 2 and 20% in Alternative 3), it would 

not compensate for the low amount of thermal cover in Trapper-Bunkhouse. However, thermal cover on 

winter range does not appear to be as important to elk winter survival as was once thought (Cook et al. 

1998). Treatments proposed in the Lower West Fork project would maintain open forest canopies and 

improve forage productivity in the understory, which may offset the loss of thermal cover (Lehmkuhl et al. 

2002, Poole and Mowat 2005). 

In HD 250, thirty-five percent of the area (250 miles2

) is winter range; 86 percent of which is on public 

land. Elk appear to use winter range on private land disproportionately more than public land (Montana 

Statewide Elk Management Plan 2004). 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-25

The Bitterroot Forest Plan requires retention of 25 percent of elk winter range in thermal cover (trees 40

feet tall and 70 percent crown closure). The Bitterroot NF proposes to adopt a site-specific Forest Plan 

Amendment for thermal cover on winter range. The proposed amendment language is located in Chapter 1 

of this document.

Analysis of Thermal Cover Forest Plan Amendment

Since implementation of the Forest Plan, it has become apparent that many portions of winter ranges on the 

Bitterroot NF are incapable of producing or sustaining the high canopy closures that provide thermal cover. 

Grasses, forbs, shrubs, and relatively open ponderosa pine and Douglas-fir/ponderosa pine stands typically 

dominate the vegetation communities on winter range. Though moister, north facing slopes and riparian 

areas provide thermal cover, most of these warm, dry habitats rarely support enough trees to qualify as 

thermal cover. In historic landscapes, thermal cover did not occupy 25 percent of elk winter ranges in the 

Bitterroot drainage. Many publications describe historic vegetation in lower elevations of the northern 

Rocky Mountains as being much more open than it currently is because of frequent fires (Gruel 1983, Arno 

1976, Gallant et al. 2003). Many lower elevation areas that are currently forested were historically

grasslands, shrub lands, or open conifer savannas (Leiburg 1899, Gruell 1983, Habeck 1994, Gallant et al. 

2003). Since none of these vegetation communities provide thermal cover (USDA Forest Service 1978), 

we infer that thermal cover on Bitterroot NF winter range was uncommon. Conifer cover, which includes 

thermal cover, has increased with fire exclusion. For example, the widespread proliferation of Douglas-fir 

on sites that were formerly ponderosa pine resulted from fire suppression and is one of the most striking 

vegetation changes on the landscape (Gruell 1983).

Several studies done in the past few years have cast doubt on the necessity for thermal cover as a major 

component of elk winter range. Recent research has shown that ungulates provided with high quality 

forage habitat in secure areas can do well without thermal cover throughout the year (Cook et al. 1998). 

This study demonstrated that energetic status, body mass, body condition, and reproductive success were 

not enhanced by thermal cover, and suggested that habitat management based on the perceived value of 

thermal cover should be reevaluated. Thus, land managers may not have to be as concerned with reducing 

forest canopy cover (including thermal cover), if they are providing high-quality foraging habitat 

(Lehmkuhl et al. 2002). Poole and Mowat (2005) also provide data that suggests the snow-intercepting 

benefits of thermal cover may not be as advantageous as forage in preferred winter habitat. In light of these 

recent findings, the presence of successfully established elk populations in areas lacking classically defined 

thermal cover imply that thermal cover requirements need further quantification (Toweill and Thomas 

2002).

Elk Habitat Effectiveness

Since the Forest Plan standard for EHE was implemented in 1987, most of the 3rd order drainages on the 

Forest have been brought into compliance through road use restrictions. Approximately 3,280 miles of 

roads have been part of the Forest transportation system. Of these, about 600 miles have been 

decommissioned and are no longer open to any motorized use. About 460 miles of system roads are closed 

to all motorized use year-round. About 644 miles of system roads are closed to full-sized vehicles yearround, but allow access by OHVs and motorcycles on either a seasonal or year-round basis. About 936 

miles of system roads remain open year-round to use by any motorized vehicle, and about 640 miles of 

system road remain open seasonally to use by any motorized vehicle. More than half of the roads that were 

once part of the Forest’s transportation system are no longer open to full-sized vehicles (J. Pintok, pers. 

comm.). Open road densities are inversely correlated with EHE, so the reduction in open road densities 

indicates a substantial, though unquantified, increase in EHE across the Forest. 

Reducing open road densities in many 3rd order drainages across the Bitterroot NF improved elk population 

numbers in the Bitterroot River watershed. Elk spring counts increased from 3,537 elk in 1987, when the 

Forest Plan was signed, to a high of 8,169 elk in 2005. Though the elk population has since declined to 

6,293 elk in 2009, the elk population increase from 1987, which is well distributed across the Forest, 
Affected Environment & Environmental Consequences - Wildlife 

3.8-26 Lower West Fork Project Final EIS 

indicates that the elk population as a whole is able to tolerate the level of open road densities and resulting 

EHE that currently exist on the Bitterroot NF.

Six of the 19 drainages in the Lower West Fork analysis area are currently below Forest Plan standards 

(Table 3.8-5). In spite of not complying with the EHE standard, the Forest Plan objective of cooperating 

with the State of Montana to maintain the current (1987) level of big-game hunting opportunities has been 

achieved. The number of hunters as well as the numbers of elk remained stable within state objectives 

prior to 2006. At about this time, FWP liberalized the hunting season to reduce the elk population to the 

State population objectives. The general hunting season has remained at five weeks; however, the harvest 

of cow elk has been reduced to improve the elk population in HD 250.

The EHE model (Lyon 1983) did not explicitly account for motorized use by OHVs and motorcycles on 

roads and trails. These types of motorized use were not considered in the development of EHE because 

they were not widely used at the time of the research. However, the increase in OHV use since the 1980s 

warrants a look at the density of roads open to all types of motorized travel. To address the effects of this

use, we calculate route density in the analysis area and define open routes as roads or trails open to any type 

of motorized vehicle during all or part of the year. We do not calculate route density by 3rd order drainage 

because Lyon (1983) recommended analyzing route density on areas greater than 3,000 acres and most of 

the 3rd order drainages are smaller than that. The route density uses the same approach described by Lyon 

(1983), but includes motorized trails in addition to roads. Road prisms that are closed to full-sized vehicles 

but open seasonally or year-round to ATVs or motorcycles are considered open routes in the route density 

calculation because motorized use of trails is assumed to affect elk in ways similar to motorized use on 

roads (Table 3.8-6). Since the original publication did not include motorized trails, route density is not 

intended to determine compliance with the Forest Plan EHE standard. Rather, it offers an additional way to 

compare alternatives. 

Table 3.8- 6: Open route density in the Lower West Fork Analysis Area. Open Road 

Densities of 2.0 miles/miles2 Equate to 50 Percent Elk Habitat Effectiveness. 

None of the ongoing or reasonably foreseeable projects will further reduce EHE. Travel management 

planning across the Bitterroot NF is occurring, however, none of the alternatives proposes changing road 

management in the Lower West Fork analysis area. 

Elk security analysis (Hillis et al. 1991) has proven to be a better tool than elk habitat effectiveness analysis 

for achieving the Forest Plan objective of maintaining elk populations and hunting season opportunities in 

cooperation with FWP. In summary, the proposed actions in combination with past and reasonably 

foreseeable actions in this analysis area are not expected to cumulatively degrade the EHE. 

A site-specific Forest Plan Amendment for Elk Habitat Effectiveness (EHE) is proposed for the Lower 

West Fork Project (Chapter 1 pg. 1-11). The Forest Plan (USDA Forest Service 1987) requires EHE, as 

measured by open road density, to be maintained at 50 percent for 3rd order drainages that were “roaded” 

and 60 percent that were “unroaded” at the time the Plan was signed. 

Analysis of the Elk Habitat Effectiveness Forest Plan Amendment

There are six, 3rd order drainages in the Lower West Fork analysis area that are currently out of compliance 

with the Forest Plan EHE standard (USDA Forest Service 1987); five of these drainages cannot meet EHE 

because the open roads access trailheads. Road decommissioning and storage in Baker Creek drainage 

under Alternatives 2 and 3 would bring this drainage into Forest Plan EHE compliance. Though seasonal 

Open route density Alt. 1 Alt 2 Alt 3

Year-round (miles/mile2) 2.8 2.2 2.0

10/15-12/15 (miles/mile2) 1.4 1.2 1.0

10/15–6/15 (miles/mile2) 2.3 1.9 1.7
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-27

road closures alleviate motorized disturbance during the hunting season, EHE is not achieved without 

closing parts of the main access roads in Lavene Creek (02e424-1), Wheeler Creek (02f427-3), east main 

Piquett (02h450-2), Violet Creek (02i450-1), and East Piquett (02h449-1) drainages. Implementation of 

Alternatives 2 and 3 require a site-specific Forest Plan amendment for EHE to remain below Forest Plan

standard for the five 3rd order drainages listed above. The roads in these 3rd order drainages are needed to 

access trailheads or areas scheduled for forest management. The remaining 14 3rd order drainages meet or 

exceed the EHE standards. Average road density in the Lower West Fork analysis area is 2.8 mi/mi2

. 

Following implementation of Alternatives 2 or 3, road density in the Lower West Fork analysis area would 

average 2.2 mi/mi2 or 2.0 mi/mi2

, respectively.

As stated above, elk populations have increased throughout the Bitterroot River watershed since the Forest 

Plan was signed. Road use restrictions implemented at the project-level improved EHE in some 3rd order 

drainages during this time, and many currently meet the EHE standard. Despite not complying with Forest 

Plan EHE standards for elk habitat effectiveness in all 3rd order drainages, the Forest Plan objective of 

maintaining the 1987 level of big-game hunting opportunities has been achieved and exceeded. The 

number of hunters has decreased slightly and Montana FWP has decreased the cow elk harvest quota but

the length of the general hunting season remains at five weeks. Because the Bitterroot NF continues to 

meet and exceed elk population objectives it appears that existing EHE is generally not a limiting factor in 

the Bitterroot drainage.

Since the establishment of the Forest Plan in 1987, four other similar site-specific amendments of the EHE 

standard have been made (Table 3.8-7). 

Table 3.8- 7: EHE Amendments to the Forest Plan since 1987

The cumulative effect of amending the EHE standard in the Lower West Fork analysis area in addition to

these previous EHE amendments would be imperceptible at the Forest scale. Many of the 3rd order 

drainages are within 10 percent of the EHE standard and the Bitterroot Valley elk population is stable. The 

MTFWP rates elk security in HD 250 as good to excellent because of the rugged terrain, road closures, and 

roadless and Wilderness areas that provide opportunities to evade hunters. Bitterroot Forest Plan objective 

and goals would continue to be met. 

There is no perceptible cumulative effect of this amendment in conjunction with the coarse woody debris or 

thermal cover portions of the amendment to the Forest Plan proposed in this project. 

None of the ongoing or reasonably foreseeable future projects listed in Appendix B would further reduce

EHE in any of the third order drainages within the analysis area. We have added an elk security analysis 

(Hillis et al. 1991) to our environmental analysis protocol that has proven to be a better tool than elk habitat 

effectiveness analysis for achieving the Forest Plan objective to maintain elk populations and hunting 

season opportunities in cooperation with Montana Fish, Wildlife and Parks. In summary, the proposed 

actions, in combination with past and reasonably foreseeable future actions in this analysis area, are not 

expected to cumulatively degrade the habitat effectiveness for elk.

Security

The fires of 2000, tree harvest, and Douglas-fir beetle epidemic on the south half of the Forest reduced 

hiding cover on winter ranges across much of the Forest. However, forage productivity increased on both 

summer and winter ranges as grasses, forbs, and shrubs responded to increased moisture and sunlight made 

available by the reduced conifer canopy. The number of elk counted in the burned elk herd units in the 

Year Number of 3rd

Order Drainages Environmental Document Ranger District

1997 2 Camp Reimel EA Sula

2001 3 Burned Area Recovery EIS Darby, Sula, West Fork

2002 5 Slate Hughes Watershed Restoration & Travel Management West Fork

2008 5 Trapper-Bunkhouse EIS Darby
Affected Environment & Environmental Consequences - Wildlife 

3.8-28 Lower West Fork Project Final EIS 

2001 spring count was comparable to the counts in 2000, despite the loss of cover caused by the fires prior 

to the 2000 hunting season. The fact that elk populations have continued to grow across the Forest despite 

these reductions in hiding cover supports the theory that abundant forage is more important to winter elk 

survival than hiding cover. 

Table 3.8- 8: Summary of Effects on Elk Habitats

Determinations

Habitat Component Alternative 1

Existing Condition Alternative 2 Alternative 3

Thermal Cover in 

winter range 21% (4% below standard) 18%1 (7% below standard) 20%1 (5% belowstandard)

Habitat Effectiveness

(50% = <2.0 mi/mi2)

6-3rd order drainages 

Exceed Standard2

NE, 5-3rd order drainages 

Exceed Standard2

NE, 5-3rd order drainages 

Exceed Standard2

Security

(% of analysis area)

53

Meets Recommendation

NE

Meets Recommendation

NE

Meets Recommendation

NE = No Effect or no change in existing condition

1

= Forest Plan Amendment needed to reduce thermal cover below Forest Plan Standard in four units. 2

= Forest Plan Amendment needed to continue to exceed EHE standard in five, 3rd order drainages. 

D. American Marten (Martes americana) (Management Indicator) & Fisher 

(Martes pennanti) (Sensitive)

American marten (also referred to as pine marten) is listed in the Forest Plan (1987) as a management 

indicator species for mature and old growth forests. Characteristics of marten and fisher habitat are 

remarkably similar (Quinn and Parker 1987; Douglas and Strickland 1987; and Jones 1991). 

Analysis Method & Reference Conditions

The analysis of marten and fisher focuses on potential and suitable habitat in the Lower West Fork analysis 

area. Marten and fisher potential habitat in the Lower West Fork analysis area is inclusively defined as 

habitat type groups C, E, F, G, and H in younger seral stages. The younger seral stages of these habitat 

types may not currently have the characteristics to be suitable habitat but have the potential to become

suitable habitat. 

Suitable habitat has the habitat components necessary to meet the needs of marten and fisher. Suitable 

habitat has the same characteristics as potential habitat but also has old growth, mature sawtimber, or multi 

storied structural components. 

Potential and suitable habitat was mapped from TSMRS/FACTS database queries and the wildlife biologist 

reviewed and verified the habitat met marten and fisher habitat requirements (PF-WL-007). For each 

alternative, four evaluation criteria were used to predict impacts to American marten and fisher. These are: 

Ø mature and old growth habitat characteristics, especially large woody debris, in potential 

and suitable habitat

Ø forest canopy closure in potential and suitable habitat

Ø effects on riparian corridors

Ø temporary disturbance in suitable habitat

Mature and Old Growth Habitat Characteristics (large woody debris)

Both marten and fisher use predominantly cooler, moister, habitat types (not habitat type groups A or B). 

Much of the preferred marten and fisher habitat resembles mature and old growth forest and dead woody 

debris is an essential component of this habitat (Strickland and Douglas 1987, Witmer 1998, pg. 14 and 

16). Resting and denning tend to occur in structures associated with late-successional conifer forests, 

whereas prey can be distributed among a variety of successional stages. Because the types of forests that 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-29

contain resting and denning sites may be more limiting, these habitats are used as evaluation criteria in this 

analysis. 

Buskirk and Powell (1994) hypothesized that tree species composition is less important to fishers than 

aspects of forest structure, which affects prey abundance and vulnerability and provides denning and 

resting sites. Such forest structures are characterized by a diversity of tree sizes and shapes; light gaps and 

associated understory vegetation; snags; fallen trees and limbs; and limbs close to the ground. A summary 

of old growth habitat and associated wildlife species in the Northern Rocky Mountains (USDA 1990, 

pg.34) cited research suggesting that at least 50 percent of female marten home range should be maintained 

in mature or old growth forest. Forest structure provides three functions important to fishers and marten: 

Ø a high diversity of dense prey populations

Ø high vulnerability of prey

Ø natal and maternal dens and resting sites 

The studies conducted in this region concluded that fishers use late successional forest more frequently than 

the early to mid-successional forests created by timber harvest (Aubry and Houston 1992, Buck et al. 1994,

Rosenberg and Raphael 1986). Similarly, fishers in the Rocky Mountain study preferred late-successional 

forests with complex physical structure, especially during the summer (Jones and Garton 1994). 

Almost all known fisher natal dens (where parturition occurs) and maternal dens (where kits are raised) 

have been discovered in Eastern North America (Arthur 1987; Paragi 1990). Of these, the vast majority 

were located high in cavities in living or dead trees. This strongly suggests that female fishers are highly 

selective of habitat for natal and maternal den sites. Information is available for only two natal dens 

(California, Buck et al. 1983; Montana, Roy 1991) and one maternal den (California, Schmidt et al. 1993, 

unpubl.) in the western United States. The den found in Montana was in an 11meters long hollow log with 

a convoluted cavity averaging 30 centimeters in diameter. Female fishers use 1-3 dens per litter (Paragi 

1990).

Forest Canopy Closure

Most studies have reported that fishers and marten prefer forests with continuous cover (Claar et al. 1999; 

Koehler and Hornocker 1977). Late-successional Douglas-fir forests of the Pacific Northwest have 

multiple layers of cover that create closed-canopy conditions (Franklin and Spies 1991). 

Koehler and Hornocker (1977) found that fires in the Selway-Bitterroot Wilderness in Idaho affected 

marten cover and food sources. The vegetation mosaic, including stringers and patches of large, unburned

trees, remaining after the fires of 1910 provided arrangement and quantities of marten food and cover; the 

living trees provided overhead cover and coarse woody debris provided den sites and subnivean (beneath 

the snow) travel lanes and hunting areas. Forest with greater than 30 percent canopy closure provided 

winter cover and foraging areas. 

Strickland and Douglas (1987) found marten did not use recent burns because habitat changes reduced prey 

populations and overhead cover. Conversely, marten and fisher continued to use areas of beetle killed trees 

when over 30 percent canopy cover remained. 

Effects to Riparian Corridors

Riparian stringers of late successional vegetation provide important connectors between habitat areas. 

Fishers use forested riparian areas extensively for foraging, resting, and as travel corridors (Claar et al. 

1999; Witmer 1998, pg. 15). 

Temporary Disturbance

Female fishers use 1-3 den sites per litter and are more likely to move litters when disturbed (Paragi 1990).
Affected Environment & Environmental Consequences - Wildlife 

3.8-30 Lower West Fork Project Final EIS 

Alternative 1

Potential Impacts to Marten and Fisher

No impact 

If high intensity fire occurs (higher 

probability with Alt. 1

Likely reduction in habitat

Alternative 2 

Potential Impacts to Marten and Fisher

May affect individuals or habitat, not likely to 

affect population viability. 

Reduced understory on 720 acres, reducing 

cover for foraging, resting or subnivean 

use.

There are approximately 4,100 acres of potential habitat in the Lower West Fork analysis area and 

approximately 13,800 acres of suitable habitat. Of the suitable habitat 4,265 acres is old growth habitat 

(PF-WL-008). Suitable fisher and marten habitat occurs relatively equal on both the east and west sides of 

the West Fork Bitterroot River on mesic, north facing aspects where continuous cover occurs. The Rombo 

fire reduced marten or fisher habitat suitability when it burned 1,423 acres of old growth on the east side of 

the West Fork River. 

Affected Environment

Alternative 1

Direct and Indirect Effects

The No Action Alternative would not change existing habitat quality for marten or fisher, either in forested 

uplands or in riparian corridors. In the short term, habitat quality would continue to improve at both lower 

and upper elevations as forests continue to mature, crown closures increase, and coarse woody debris 

accumulates. In the longer term, increasing tree densities 

and fuel loads would increase the probability of a large, 

intense fire. A large fire would create unsuitable habitat 

for marten and fisher in areas that burned with moderate 

and high intensities as occurred in the Rombo fire.

Mature and Old Growth Habitat Characteristics, Canopy Closure & Riparian Corridors

No temporary disturbance would occur.

Temporary Disturbance

Alternative 2

Alternative 2 proposes treatments on approximately 720 

acres of potential marten and fisher habitat and approximately 2,500 acres of potentially suitable habitat 

(18% of suitable habitat in analysis area). 

All the treatments within the approximately 3,220 

acres of potential and suitable habitat would reduce 

fuels, reducing the risk from high intensity fires that 

would convert large areas of mature and old growth 

habitat to early seral stages. Open, early seral habitat 

is not generally used by these species (Aubry and 

Houston 1992). 

Mature and Old Growth Habitat Characteristics

Approximately 260 acres of treatments in Alternative 2 

would occur in suitable marten and fisher habitat that 

meets old growth habitat characteristics (Old Growth 

section). Old growth characteristics will be retained after treatments. The treatments would facilitate 

retention of currently suitable habitat over a sustained period. Stand level prescriptions by a certified 

silviculturist, fuels specialist, and wildlife biologist and the silviculturist and wildlife biologist monitoring 

the treatments would assure old growth habitat characteristics are retained. 

Approximately 2,500 acres of suitable marten and fisher habitat would be treated using intermediate 

harvest, intermediate harvest and burning, or prescribed burning. The treatments are designed to retain the 

mature to old growth habitats and reduce the risk of stand replacing fires. Downed woody debris and snags 

would be reduced; however, mitigations will assure sufficient quantities are retained for marten and fisher 

habitat needs. The treatment designs would retain the overstory stand component.
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-31

Harvest, slashing, or prescribed fire would be used to reduce ladder fuels and stand density in the

understory. This could reduce marten and fisher foraging, resting or subnivean use in these areas (Huggard 

1999). Research has shown marten use partially harvested stands but at greatly reduced frequency 

compared to unharvested stands (Huggard 1999, pg. 11 & 12; Harrison 2004, PF-WL-009). Improved 

residual tree growth following harvest and the removal of competition, may produce denser canopies and 

provide better habitat faster than if no reduction in competition occurred (Huggard 1999, p. 12).

Downed woody material would also be reduced in these units. However, mitigation measures would retain 

adequate amounts of woody debris as described in Section 1.4.1 and in Section 2.3. In each unit, between 

five and 18 tons per acre of coarse woody debris would be left, depending on the habitat type of the unit. 

These standards are based on what would be expected in these habitat types (Graham et al. 1994). 

Additionally, all snags that do not pose an OSHA safety hazard would be retained in each unit. Both snags 

and woody debris would be irregularly distributed and retained in clumps, which is a desirable habitat 

feature. The retention of snags and downed logs would provide adequate sites for travel, resting, hiding 

cover, prey habitat, hunting, subnivean chambers, and denning activities.

Approximately 720 acres of potential habitat would be treated using non-commercial or commercial 

thinning with or without prescribed fire, and prescribed fire alone. Much of this area appears to be 

currently unsuitable for marten or fisher. Many of these stands are too young to provide suitable habitat 

and therefore thinning would not directly or indirectly affect marten or fisher. Thinning in these younger 

stands enhances stand growth and development that would hasten the development of suitable marten and 

fisher habitat structure. The prescriptions are designed to accelerate the growth, form, and vigor of the 

stand. 

Generally, all treatments would retain between 40 to 95 percent of the live overstory after harvest. The 

existence of 30 percent or greater canopy closure after treatment would depend on the pre-treatment 

condition. Some stands have lost live canopy to endemic populations of insect and disease and the Rombo 

fire. Marten and fisher do not use open canopy areas for resting or denning. 

Canopy Closure

Riparian corridors will be protected through implementation of the Inland Native Fish Strategy guidelines. 

Continuous cover and riparian stringers that facilitate fisher and marten movement and dispersal would be 

retained under these guidelines. Following the guidelines requires that trees are not harvested within 300 

feet of fish bearing streams; 150 feet of permanently flowing, non-fish bearing streams and ponds, lakes or 

wetlands; and 100 feet around intermittent streams or wetlands less than one acre (See Section 2.5).

Effects to Riparian Corridors

If activities occur within a marten or fisher occupied home range, the animals may be displaced or 

disturbed. Alternative 2 proposes treatment in approximately 18 percent of the suitable habitat in the 

Lower West Fork analysis area, meaning 82 percent of the suitable habitat and 100 percent of the riparian 

corridors will not have management activities and could be available for displaced individuals 

Temporary Disturbance

Alternative 3

Alternative 3 proposes treatments on approximately 450 acres of potential marten and fisher habitat and 

approximately 1,950 acres of suitable habitat (14%) of the total habitat in the analysis area. 
Affected Environment & Environmental Consequences - Wildlife 

3.8-32 Lower West Fork Project Final EIS 

Alternative 3 

Potential Impacts to Marten and Fisher

May affect individuals or habitat, not likely to 

impact population viability. 

Reduced understory on 450 acres, reducing 

cover for foraging, resting or subnivean 

use.

If high intensity fire occurs (slightly greater 

probability as compared to Alternative 2)

Likely reduction in habitat

All the treatments within the approximately 2,400 acres 

of habitat would reduce fuels. The analysis shows that 

the risk from high intensity fires that could convert large 

areas of mature and old growth habitat to early seral 

stages is negligible in Alternative 3 compared to 

Alternative 2. If a high intensity fire reduces canopy 

cover below 30 percent, suitable marten and fisher habitat 

would be reduced (Brown and Reinhardt 2001). 

Strickland and Douglas (1987) found marten did not use 

recent burns because habitat changes reduced prey 

populations and overhead cover.

Mature and Old Growth Habitat Characteristics

In Alternative 3, approximately 228 acres of old growth

suitable marten and fisher habitat would be treated (see 

Old Growth section). Old growth habitat characteristics 

would be retained after treatments. The treatments would facilitate retention of currently suitable habitat 

over a sustained period. The silviculturist and wildlife biologist will monitor treatments in old growth 

stands to assure old growth habitat characteristics are retained. 

Approximately 1,950 acres of suitable marten and fisher habitat would be treated using intermediate 

harvest, intermediate harvest and burning, or prescribed burning. All of these treatments are designed to 

retain the overstory stand component. The understory vegetation would be reduced to decrease ladder fuels 

and stand densities. Marten and fisher foraging, resting or subnivean use may be reduced in these areas 

(Huggard 1999). Though marten use partially harvested stands, the frequency of use is greatly reduced 

compared to unharvested stands (Huggard 1999, pg. 11 & 12; Harrison 2004). Improved residual tree 

growth following harvest may produce denser canopies and provide better habitat faster than if no 

reduction in competition occurred (Huggard 1999, pg. 12).

Downed woody material and snags would also be reduced in these units. However, mitigation measures 

have been designed to retain adequate amounts of woody debris as described in Section 1.4.1 and in 

Section 2.3. The retention of snags and down logs would provide adequate sites for travel, resting, hiding 

cover, prey habitat, hunting, subnivean chambers, and denning.

Approximately 450 acres within potential habitat would be treated using non-commercial or commercial 

thinning with or without prescribed fire, or prescribed fire alone. Under Alternative 3, treatment would

occur in approximately 12 percent of the suitable habitat in the Lower West Fork analysis area, leaving 88

percent of the suitable habitat and 100 percent of the riparian corridors to serve as habitat for individuals 

displaced by management activities. Alternative 3 would have the same effects on marten and fisher 

habitat as Alternative 2, except about one quarter fewer habitats would be treated.

Geographic Boundaries and Time Period 

Cumulative Effects

The Lower West Fork analysis area defines the marten and fisher cumulative effects analysis area. This 

area is appropriate to analyze the incremental project effects on these species in conjunction with past, 

present, and reasonably foreseeable actions. An assessment of information available at the Forest level is 

also considered to provide additional context.

The size of marten and fisher home ranges determined the cumulative effects analysis area. With a home 

range size between 370 and 16,800 acres for males and 100 to 1,800 acres for females (Foresman 2001), it 

is reasonable to assess effects within the 13,800 acres of suitable habitat in the 38,000-acre Lower West 

Fork analysis area. Theoretically, between 1 and 138 home ranges could fit within the suitable habitat in 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-33

the Lower West Fork. Incremental effects of proposed activities of this project to home ranges outside the 

analysis area would not be measurable. 

Under Alternative 1, long-term (several decades) indirect effects would occur if another high intensity fire, 

like the Rombo fire, burns an extensive portion of the mature or old growth habitat. Fire would convert the 

forest to early seral stages and reduce marten and fisher habitat suitability for several decades to over 100 

years, depending on fire intensity. 

Alternatives 2 & 3 

Ø Reduction in understory canopy– would reduce habitat suitability for approximately 25 –

50 years. Fire or vegetation management could extend this effect. 

Ø Reduction in downed woody debris – could be expected to last for several decades in 

treated stands where the dead and dying fuel is removed. Fuels are not being treated in 

82% of the area in Alt. 2 and 88% of the analysis area in Alternative 3. 

Ø Timber harvest may reduce crown canopy in proposed units in Alternative 2 and 3. It 

may require 25 – 50 years for the canopy to fill in 30%. 

Ø Temporary disturbance in suitable habitat –during periods of active management,

temporary displacement could occur for the duration of the activity. Studies have 

documented use of partially harvested areas by marten after harvest; however, the use 

was substantially less than in un-harvested habitat. There are 17,900 acres of suitable 

habitat available within and outside the analysis area to which individuals could, 

theoretically, be displaced.

Other Actions

Private and State land is generally not important to maintain suitable marten or fisher habitat since much of 

the land is typically at lower elevations that are generally too dry to support marten or fisher habitat. Fire 

suppression has modified forest structure and composition. Data indicates that in the Lower West Fork 

area, there is more mature Douglas-fir relative to what was present historically. 

Between 1938 and 1942, four percent of the Bitterroot NF sawtimber was Douglas-fir compared to the 

current 26 percent (Samson 2005, pg. 58). Marten habitat includes dense, mature Douglas-fir, so 

theoretically marten and fisher habitat may be more extensive today than between the early 1900s through

1940s. The buildup of fuels from fire suppression suggests that fire would be uncharacteristically severe in 

size and intensity if it occurs. A large, intense fire could reduce large areas of marten habitat as occurred in 

2000 on the Bitterroot NF (USDA 2000 – Post fire assessment pg. 4.4 Wildlife-8) and the Rombo fire. The 

natural fire regime in marten and fisher habitat would have been mixed intensity with smaller areas of stand

replacing fires. These types of fires created mosaics of mature forest for denning sites, with islands of 

unburned forest within burned areas that may have increased populations of voles or other prey. This was 

the pattern observed in the Selway-Bitterroot Wilderness as a remnant of the 1910 fires (Koehler and 

Hornocker 1977).

Past harvest in the Lower West Fork analysis area created non-forest cover, relative to marten and fisher 

habitat requirements, on more than 25 percent of the area. In the 1980s, forest practices changed and

higher levels of downed woody debris and snags, important marten and fisher habitat components, were 

retained in harvest units. Hargis (1999) suggested marten and fisher may be vulnerable to habitat 

fragmentation and, in one study, were nearly absent from landscapes having greater than 25 percent nonforest cover, both natural openings and openings created by harvest (Hargis 1999). Most of the area 

harvested prior to the 1980s has reforested, improving marten and fisher habitat conditions. 

Marten are notoriously vulnerable to trapping. Marten trapping occurs on the Bitterroot NF and some 

marten trapping probably occurs within the Lower West Fork analysis area. No foreseeable activities 

(Appendix B) in the Lower West Fork analysis area are expected to affect marten or fisher habitat.
Affected Environment & Environmental Consequences - Wildlife 

3.8-34 Lower West Fork Project Final EIS 

Trends & Broader Context

The Montana Natural Heritage Program classifies the pine marten as a G5 S4 species. This means that at 

the global scale, marten are common, widespread, abundant, and not vulnerable in most of their range. At 

the state scale, marten are uncommon but not rare, and usually widespread. They are apparently not 

vulnerable in most of their range but there is a possible cause for long-term concern. University of 

Montana mammalogist, Kerry Foresman, found marten are common in Montana and occur throughout the 

western and southwestern parts of the state (Foresman 2001). FWP trapping records indicate that between 

1996 and 2006, the average number of marten taken by trappers annually was 1,525 across Montana, 457

within FWP District 2, and 201 within Ravalli County (PF-WL-011).

At a Forest wide scale, Samson (2006) estimates we have approximately 393,400 more acres of marten 

habitat than is necessary to maintain a minimum viable population. For Alternatives 2 and 3 the potential 

reduction in suitability would amount to less than 2 percent and 1 percent, respectively, of the 410,700 

acres of habitat on the Forest.

Forest biologists have rated the suitability of marten habitat across the Forest. Considering all the area 

rated, the Habitat Suitability Index for marten was calculated at 0.32. This index tells us that on average, 

marten habitat on the Bitterroot NF (at least the 190,000 acres rated for suitability) is about 1/3 as good as 

the best marten habitat. This implies that marten are likely to occur in low densities in suitable habitat 

throughout the Forest. However, marten populations are likely to be robust in the corridors of high quality 

habitat that exist along many of the larger streams draining the Bitterroot Mountains. Lacy and Clark 

(1993) used computer simulations to show that marten populations are sustainable over time if a small 

number of migrants into the breeding pool maintained genetic variation, even in the face of trapping and 

logging.

The Bitterroot NF has been monitored marten populations since 1988. The Forest surveyed nearly 750 

miles of transects between 1988 and 1996. In that period, an average of one marten track every 6.7 miles 

was observed. Variation between transects was high, ranging from one track every four miles to one track 

every eleven miles. The 1988-1996 data established a base line population index with which to compare 

future information. Each Ranger District has established permanent pine marten monitoring routes. Nine 

marten transects were completed in 2004. The average number of miles surveyed per marten track in 2004 

was considerably lower than the average from 1988 to 1996. In other words, more marten tracks were seen 

in 2004 than in baseline. This apparent increase could mean that marten numbers have increased 

dramatically, but could also be a result of other sampling or environmental variables, not the least of which 

is the effect of pelt price on trapping activity. During years of abundant food supply, population densities 

of marten increase, which could be another factor (USDA 1990, pg. 34). Pine marten population densities 

and trend information is limited to that reported in the current Forest Plan Monitoring Report (USDA 2007, 

PF-WL-012). The information is not sufficient to ascertain population densities or trends, but pine marten 

tracks have been detected on all the established monitoring routes indicating pine marten are well 

distributed across the forest. This distribution of habitat should allow individual martens to interchange 

between habitat patches (USDA 1990, pg. 34).

According to FWP trapping records, between three and five fisher have been trapped each year for the past 

eight years in the Bitterroot Valley. All records are from the west side canyons, with a few exceptions 

north of the Rye Creek drainage. 

Determination

Alternative 1 (No Action)

Implementation of this alternative would have no impact on marten or fisher or their habitat.
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-35

Alternative 2 and Alternative 3

Implementation of Alternative 2 and 3 may impact individual marten or fisher or their habitat, but would 

not likely contribute to a trend towards Federal listing or loss of viability to population or species.

Rationale for Determination

Ø There are no measurable impacts with implementation of Alternative 1.

Ø Because the potential effects of Alternatives 2 and 3 are so limited, in the context of the 

apparently adequate and excess habitat Forest wide, the predicted impacts to potential 

and suitable marten and fisher habitat would not likely influence population or species 

viability.

Ø Alternatives 2 and 3 would adhere to downed woody debris and snag mitigations and 

RHCA protections which would retain adequate amounts of large woody debris and 

snags for marten and fisher travel, resting, hiding cover, prey habitat, hunting and 

denning. 

Ø Project design in Alternatives 2 and 3 are generally to retain the largest, overstory trees. 

Ø If marten or fisher occupy an area where treatment occurs, there is other suitable habitat 

in the Lower West Fork to which they could be displaced. 

Ø Forest monitoring information indicates marten are present and appear to be well 

distributed (USDA 2007, PF-WL-012).

E. Pileated Woodpecker (Dryocopus pileatus) (Management Indicator) 

The pileated woodpecker analysis focuses on the potential and suitable habitat in the Lower West Fork 

analysis area. Potential habitat on the Bitterroot NF is defined as habitat type groups A, B, C, and G below 

6,200 feet in elevation, in young seral stages (seedling, sapling, and pole). These stands have the potential 

to develop characteristics of suitable habitat. Suitable habitat currently has the habitat components 

necessary to meet the needs of pileated woodpeckers. Suitable habitat has the same features of potential 

habitat except it is in more mature seral stages (mature, saw timber, multi-storied, or old growth structural 

components). 

Effects Analysis Methods & Reference Condition

Potential and suitable habitat was mapped from TSMRS/FACTS database queries and the wildlife biologist 

with knowledge of pileated woodpecker habitat requirements reviewed and verified the habitat met habitat 

requirements (PF-WL-013). For each alternative, two evaluation criteria were used to predict impacts on 

pileated woodpecker. These are: 

Ø Nesting habitat availability – the presence of large snags, especially ponderosa pine snags

Ø Food source – the presence of downed woody material and snags for prey habitat

Nesting Habitat Availability – Large Snags and Ponderosa Pine

Dead trees large enough to accommodate a nest cavity are important for pileated woodpecker habitat 

(Terres 1980). The pileated woodpecker is most often associated with mature forests (Conner et al. 1979, 

Conner 1980, Shackelford and Conner 1997) though the presence of large trees for nesting appears to be 

more important than forest age (Kirk and Naylor 1996, Giese and Cuthbert 2003). The pileated 

woodpecker may be able to do well in young and fragmented forests with abundant remnant (older) 

structure (Mellon et al. 1992). However, some studies have shown pileated woodpeckers respond 

negatively to forest fragmentation, though whether older structure was retained in those studies is not clear 

(PF-WL-014). Bonar (2001) reported pileated woodpeckers use areas with 10 percent cover. 

Pileated woodpecker nest snags are often greater than 21 inches diameter at breast height (dbh) and the 

cavity is most often more than 40 feet above the ground (Bull and Jackson 1995). There are indications 

that pileated woodpeckers prefer ponderosa pine over Douglas-fir. At Coram Experimental Forest in 
Affected Environment & Environmental Consequences - Wildlife 

3.8-36 Lower West Fork Project Final EIS 

Alternatives 1

Potential Impacts to Pileated 

Woodpecker

No impact to pileated woodpecker or 

their habitat

northwestern Montana, McClelland and McClelland (1999) found that pileated woodpecker preferred 

western larch (n=52), which is not found in the Lower West Fork, and ponderosa pine (n=18). Other 

species used included black cottonwood (n=15), aspen (n=7), western white pine (n=1), grand fir (n=1), 

and Douglas-fir (n=1). Nest trees were similar in size to roost trees and both were typically snags with 

broken tops, 81 and 78 percent, respectively (McClelland and McClelland 1999). Broken tops indicate the

snags were rotten. Hutto (1995) supported the findings of McClelland and McClelland (1999) but he also 

reported they use mixed conifer and cedar-hemlock stands.

Altered fire regimes effect species composition, favoring shade tolerant species like Douglas-fir and 

inhibiting shade intolerant species like western larch and ponderosa pine. The range of western larch does 

not extend into the Lower West Fork analysis area. Researchers have stated that if altered fire regimes 

reduce the abundance of large, old western larch, they are likely to impact the pileated woodpecker as well 

(Smith et al. 2000, p. 49). It is reasonable to assume, then, that if fire regimes reduce the abundance of 

large, old ponderosa pine, it may also reduce woodpecker’s habitat.

Food Source – Downed Woody Material and Snags

Carpenter ants are very important for pileated woodpecker habitat (Bull and Jackson 1995). Pileated 

woodpeckers often feed on ants, other insects, and larvae in coarse woody debris and snags. In winter, the 

pileated woodpecker excavates relatively sound wood around the base of a snag or tree in search of 

carpenter ants. 

There are approximately 2,100 acres of potential habitat and 10,500 acres (28% of the analysis area) of

suitable habitat in the analysis area. Based on site-specific stand characteristics such as large trees, coarse 

woody debris or logs, and broken topped trees, the quality of the suitable habitat may range from poor to 

good in the Lower West Fork analysis area. This conclusion is based on past project analysis with the most 

recent being the directly adjacent Trapper Bunkhouse project. The Trapper Bunkhouse project reported a 

pileated woodpecker Habitat Suitability Index (HSI) rating of 27%. An HSI rating of 27% indicates that 

overall, the analysis area provides poor to fair pileated woodpecker habitat. 

Affected Environment

The fires in 2000 and the Rombo fire, along with endemic insect populations have created numerous snags, 

many of which are and will become suitable cavity building sites within the next decade. As snags fall, the 

coarse woody debris will provide ideal foraging logs for 

pileated woodpeckers. 

Direct and Indirect Effects1

Alternative 1

The No Action Alternative will not cause short-term changes

in pileated woodpecker habitat because no green trees, down 

woody material, or snags would be removed. 

Nesting Habitat Availability; Food Source 

Fires will continue to ignite in the area and the high fuel loads increase the potential for large-scale, high 

intensity fires. The literature suggests that pileated woodpeckers are not associated with severe fire 

landscapes (Hutto 1995), and do not nest in areas of recent stand replacing fires (Smith 2000, pg. 49). 

However, monitoring on the Bitterroot NF after the burns of 2000 showed a slight increase each year in the 

 

1 Potential effects to pileated woodpecker habitat correspond with effects to old growth and snags that are within their 

habitat type. See those discussions in Section 3.8.5 A and B.
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-37

Alternatives 2

Potential Impacts to Pileated 

Woodpecker

May impact individuals or their habitat, 

not likely to impact population 

viability

Project design and mitigations retain 

adequate snags and downed wood for 

nesting and foraging habitat, though 

use in treatment units may be reduced

Ponderosa pine is favored in treatment 

units.

number of pileated woodpecker detections per mile between 2000 to 2003; despite the fact that several 

transects were extensively burned. The number of detections may be due to the lack of foliage to muffle 

the sound that would normally make hearing difficult. Therefore, the effect of a severe fire is uncertain, but 

it is possible it would reduce habitat for this species. 

Alternative 2

Alternative 2 proposes treatments on approximately 700 acres of potential habitat and 3,000 acres of 

suitable habitat.

Approximately 250 acres of treatments in Alternative 2 

would occur in potential pileated woodpecker habitat that 

meets old growth habitat characteristics. Old growth 

characteristics will be retained after treatments. These 

treatments are beneficial because they would reduce the risk 

that large potential nest trees would be lost during a fire. The 

wildlife biologist and or silviculturist will monitor treatments 

in old growth stands to assure old growth habitat 

characteristics are retained.

Nesting Habitat Availability – Large Snags and Ponderosa Pine

Non-commercial tree thinning would not affect pileated 

woodpecker habitat quality in the short term because these 

treatment areas do not contain pileated woodpecker habitat 

components. In the long term, these treatments would 

accelerate restoration of larger forest size classes that could 

provide suitable habitat for pileated woodpeckers.

Average pileated woodpecker territory size would likely increase because the proposed treatments would 

reduce habitat quality within some territories. As a result, the pileated woodpecker carrying capacity in the 

analysis area would be less than the existing condition. The reduction in carrying capacity is not 

quantifiable but is likely to be small.

In the long term, this alternative would reduce the potential of large, high intensity fire that could reduce 

the amount of suitable pileated woodpecker habitat in large portions of the analysis area. This alternative 

would move treated stands towards mature or old growth conditions in the long term by reducing the high 

stocking densities and removing ladder fuels that contribute to the risk of stand replacing fire. Most of the 

treatments would occur in ponderosa pine stands, which develop more desirable old growth conditions for 

pileated woodpeckers than more shade tolerant species such as Douglas-fir or subalpine fir.

No snags would be removed unless they present an OSHA defined safety hazard. This should retain 

potential nesting sites within the historic range of the particular habitat type. No harvest would occur 

within the RHCA. Ponderosa pine and large snags will be favored for snag retention in appropriate habitat 

types. In other words, trees potentially important to pileated woodpeckers for nesting will be retained 

through project design and mitigation. Thinning from below, designed to emulate understory fire in 

reducing fuels in an old-growth forest in Oregon, did not alter use of the site by pileated woodpeckers (Bull 

and others 1995). Monitoring of recent vegetation management activities (PF-WL-006) along with several 

other projects indicate snag retention prescriptions are consistently met. 

Downed woody material would be reduced in treated units. Reduction in habitat quality would be most 

pronounced in commercial and prescribed fire treatments. Pileated woodpecker habitat would remain 

suitable in these units but habitat quality would decline because the treatments would reduce the amount of 

downed woody debris available for foraging. An Oregon study showed that pileated woodpeckers foraged 

Food Source – Downed Woody Material and Snags
Affected Environment & Environmental Consequences - Wildlife 

3.8-38 Lower West Fork Project Final EIS 

Alternative 3

Potential Impacts to Pileated 

Woodpecker

May impact individuals or their 

habitat, not likely to impact 

population viability

Project design and mitigations retain 

adequate snags and downed 

wood for nesting and foraging 

habitat, though use in treatment 

units may be reduced

much less in units that had been burned using prescribed fire because these units contained less dead wood 

habitat for ants (Bull et al. 2005). However, mitigations are designed to retain adequate amounts of woody 

debris. It is reasonable to assume that historic levels of downed woody debris would provide suitable 

pileated woodpecker foraging habitat.

The literature presents contradicting information on pileated woodpeckers use of harvested stands. The 

details of the types of treatments may be a key factor. Research in Oregon found pileated woodpeckers 

used stands treated mechanically but not burned more than they used stands that had been broadcast burned 

one to three years after fuel reduction treatment (Bull et al. 2005). They found that “both the control 

treatments and the mechanical removal treatments provided significantly more foraging habitat for pileated 

woodpeckers, whereas the prescribed burn treatments provided significantly less” (Bull et al. 2005, p. 11). 

This was correlated with the abundance of ants in the downed woody material. 

In Mississippi, however, pileated woodpeckers foraged extensively on logs in an area that burned 2 weeks 

earlier; an abundant food supply of wood-boring beetles appeared to be the primary attraction (Smith et al. 

2000, pg. 22). In British Columbia, they found no difference in woodpecker foraging among treatments 

after partial harvesting and burning in the short term (1 to 2 years) (Bull et al. 2005). In Idaho and 

Montana, Young and Hutto (2002) found no difference in pileated woodpecker occurrence of in stands that 

had been partial-cut (thinned, shelterwood, seed tree) and unharvested control areas. This was different 

than Hutto’s findings in an earlier study (Hutto and Young 2000), however the treatments in the earlier 

study were different from prescriptions in Alternative 2; no understory vegetation was removed, only the 

mature overstory. 

In summary, the Alternative 2 treatments may temporarily (1-3 years) reduce pileated woodpecker foraging 

habitat.

If pileated woodpeckers are present they could be temporarily displaced during activity, however there are 

ample opportunities within the analysis area and adjacent areas for dispersal.

Alternative 3

Alternative 3 proposes treatments on approximately 370 acres of potential habitat and 2,000 acres of the 

suitable habitat.

Approximately 200 acres of old growth suitable habitat would be 

treated in Alternative 3. Old growth characteristics would be 

retained after treatments. These treatments are beneficial because 

they would reduce the risk that large potential nest trees within 

old growth habitat would be lost during a fire. The wildlife 

biologist and silviculturist will monitor treatments in old growth 

stands to assure old growth habitat characteristics are retained

after treatment. 

Nesting Habitat Availability – Large Snags and Ponderosa Pine

Alternative 3 reduces fuels on 1,327 fewer acres than Alternative 

2 on the east side of the West Fork River. The effects of 

Alternative 3 are the same as Alternative 2 on the west side of the 

West Fork River. The risk of losing suitable pileated woodpecker 

habitat would continue to be high on the east side of the West 

Fork River. 

Downed woody material would be reduced in treated units. However, mitigations are designed to retain 

adequate amounts of woody debris. In each unit, between 5 and 24 tons per acre of coarse woody debris 

would be left, depending on the habitat type (Section 1.7D). These standards are based on what would be 

Food Source – Downed Woody Material and Snags
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-39

expected in these areas according to habitat type (PF-WL-010). It is reasonable to assume that historic 

levels of downed woody debris would be suitable for pileated woodpecker foraging. 

Alternative 3 effects are similar to Alternative 2. Treatments in Alternative 3 may temporarily (1-3 years) 

reduce pileated woodpecker foraging habitat. As in Alternative 2, if pileated woodpeckers are present they 

could be temporarily displaced during vegetation treatments.

Cumulative Effects 

The Lower West Fork analysis area is the pileated woodpecker cumulative effects area. The area is 

appropriate to analyze the incremental effects of project activities on pileated woodpeckers in conjunction 

with past, present, and reasonably foreseeable actions. An assessment of the habitat and population 

viability at the Forest level provides additional context. 

Geographic Boundaries and Time Period

The size of pileated woodpecker territories determined the cumulative effects analysis area. Territory size 

reported in the literature varies considerably. Estimated territory sizes ranges from 500 – 1,000 acres in 

western Montana (McClelland 1979), 320 – 600 acres with a mean size of 543 acres in northeastern Oregon 

(Bull and Meslow 1977, 1988), 1,006 acres in northeastern Oregon (Bull and Holthausen 1993), and 3,361 

acres in Alberta (Bonar 2001). The 10,500 acres of suitable habitat in the Lower West Fork analysis area is 

a reasonable area to assess effects assuming the territory size estimate from the Montana study is most 

relevant. Incremental effects of proposed activities of this project to nesting territories outside the analysis 

area would not be measurable. Evaluating effects at the Forest level provides a broader context for the 

local effects. 

For Alternative 1, more snags would be available for nesting and more downed wood available for foraging

as trees continue to grow and die. If a large-scale and severe fire occurs in the area, it could reduce the 

amount of pileated woodpecker habitat for up to 100 years, until forest regenerated and trees grew to 

suitable nesting size. 

Alternative 2 & 3 

In general, snags are at an unprecedented level across the Bitterroot NF (USDA Forest Service 2000a, p.4.4 

Wildlife 8, 9). Douglas-fir snags, in particular, are available in the analysis area and throughout the south 

end of the Bitterroot NF due to Douglas-fir bark beetle mortality. Prescriptions are designed to favor 

retention of ponderosa pine trees and snags, which pileated woodpeckers prefer for nesting over Douglasfir. Pileated woodpeckers are known to nest in 10 percent cover if the nest tree is appropriate (Bonar 

2001), but appear to prefer nest trees in areas that provide relatively high basal areas (100 – 125 square feet 

per acre) and closed canopies (McClelland 1977). The effect of a reduction in nest trees, which would be 

predominantly Douglas-fir, is assumed to be only a temporary impact, as other appropriate nest trees are 

available. 

Where ponderosa pine already exist, the protection of those trees by removal of competition and fuel 

reduction activities would benefit pileated woodpecker habitat for approximately 25 – 50 years or until the 

next fire disturbance or vegetation management occurs. 

The amount of downed woody debris left after treatments would be sufficient for pileated woodpecker

foraging. If charring of the wood reduces ant use, and therefore foraging habitat, the effect would last until 

new downed woody material was available. 

Pileated woodpeckers may be vulnerable to the repeated action of fire suppression, which modifies forest 

structure, and composition (Hejl white paper, PF-WL-015, 2004 Monitoring Report, PF-WL-016). In 

recent decades, fire suppression in coniferous forests has increased the dominance of shade-tolerant 

species. Historically, ponderosa pine was dominant or co-dominant in these forests and is preferred

Other Actions
Affected Environment & Environmental Consequences - Wildlife 

3.8-40 Lower West Fork Project Final EIS 

pileated woodpecker nesting habitat. This has led to a loss or considerable reduction of a preferred nest 

tree. 

The loss of ponderosa pine trees and snags appropriate for nest cavities through harvest or firewood cutting 

is a repeated impact. We suspect that habitat quality for this species declined in the early 1900s across the 

Forest when mature ponderosa pine habitats were extensively clearcut (2004 Monitoring Report, PF-WL016). Habitat fragmentation may have also impacted habitat quality (PF-WL-015 – Hejl). Past timber 

harvest practices within the Lower West Fork analysis area, where the largest trees were taken, reduced the 

numbers of large snags available to pileated woodpeckers. 

Since the 1980s, snag retention guidelines have reduced the loss of potential nesting snags in harvest units. 

Monitoring recent vegetation management activities (Burned area recovery monitoring PF-WL-006),

indicates snag retention prescriptions have been consistently met. Samson (2005, pg. 60), states that timber 

management in the Northern Region in 2004 amounted in total to 0.0009 percent of the landscape, and is 

not affecting short-term species viability. 

Repeated grazing in some areas may affect pileated woodpecker habitat. In British Columbia, the 

compounded effects of livestock grazing and fire suppression reduced ponderosa pine regeneration. The 

Piquett grazing allotment is currently vacant and used intermittently. Livestock grazing in the Lower West 

Fork analysis area would not interfere with ponderosa pine regeneration. None of the foreseeable activities 

(App. B) in the Lower West Fork analysis area would affect pileated woodpecker habitat. 

Stand replacing fire could eliminate large areas of potential habitat as seen in the assessment of post-fire 

conditions (USDA 2000 p. 4.4 Wildlife – 8). In low intensity fire, most of the canopy would remain alive 

but occasional or small patches or trees would be killed. This may be ideal habitat for pileated 

woodpeckers, especially in habitat type groups A, B, C, and G.

The Montana Natural Heritage Program classifies the pileated woodpecker as a G5 S4 species. This means 

that at the global scale, pileated woodpeckers are common, abundant, and not vulnerable in most of their 

home range. At the State scale, they are uncommon but not rare and usually widespread. They are 

apparently not vulnerable in most of their range but there is possible cause for long-term concern.

Trends & Broader Context

Regional habitat models using FIA data estimate that the Bitterroot NF contains sufficient suitable nesting 

habitat to support about 91 pairs of pileated woodpeckers, and enough winter foraging habitat to sustain 

almost 800 pairs (Samson 2005). This habitat is well-distributed across the Bitterroot NF at lower to midelevations. Habitat estimates only include National Forest, which provides about 86 percent of the habitat 

necessary for a minimum viable population, or about 180 individuals (Samson 2006). Additional nesting 

habitat for pileated woodpeckers is located on private lands in the mixed cottonwood and ponderosa pine 

forests along the Bitterroot River and many of its larger tributaries. These bottomland forests provide some 

of the most productive habitat for this species, and serve to connect subpopulations in the surrounding 

mountains. The presence of large amounts of high quality habitat on private land indicates that the 

Bitterroot drainage is capable of supporting a much larger population of pileated woodpeckers than 

indicated by estimates from Bitterroot NF lands alone.

At the Regional scale, habitat modeling estimates there is enough suitable nesting habitat to support about 

2,362 pairs of pileated woodpeckers, and enough winter foraging habitat to sustain about 19,430 pairs of 

birds (Samson 2005). Again, this estimate does not include the high quality habitat located along the river 

and stream corridors on private land. Pileated woodpecker median dispersal distance is estimated at 150 

miles, which indicates that pileated woodpeckers across the entire Region belong to a single, wellconnected population. The Forests neighboring the Bitterroot NF to the north and west have pileated 

woodpecker habitat in excess of the quantity modeled to maintain a minimum viable population on their 

Forests alone (Lolo -165%, Clearwater -346%, and Nez Perce -459%). Although no population estimates 

are available, the large amount of apparently suitable habitat well distributed across the Region combined 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-41

with the interconnectedness of the population indicates that short-term viability of pileated woodpeckers 

across the Region is not an issue (Samson 2005).

The largest legacy effects on habitat in the Lower West Fork area may have been fire suppression and 

historic harvesting practices that removed snags or downed woody material. Prior timber harvests, fires, 

and fire suppression do not appear to have affected species viability because monitoring indicates pileated 

woodpeckers are present on all monitoring transects. Pileated woodpecker population information on the 

Bitterroot NF is based on call count transects reported in the Forest Plan Monitoring Report (PF-FPMON035). The information is not sufficient to establish population densities or trends, but the number of 

pileated woodpeckers detected per mile of transect has generally increased since 2000. Pileated 

woodpeckers appear to be common and well distributed at low to mid-elevations across the Bitterroot NF

as indicated by frequent detections of their unique foraging excavations and calls. 

Samson (2005) states that “habitat estimates for the pileated woodpecker based on the Regional nest tree 

habitat model show nest site habitat is abundant and well distributed across the Northern Region by 

National Forest.” Samson also states, “habitat on today’s landscape is very abundant for the pileated 

woodpecker.” 

Most of the recent Bitterroot NF management in lower elevation forests emphasizes restoration of mature 

ponderosa pine habitats, which should benefit pileated woodpeckers over time according to our Forest Plan 

Monitoring Report (USDA, 2003). Alternatives 2 and 3 would contribute to this trend. 

Alternative 1 (No Action)

Determination

Implementation of this alternative would have no impact on pileated woodpeckers or their habitat.

Alternative 2 and Alternative 3

Implementation of Alternative 2 and 3 may impact individual pileated woodpeckers or their habitat, but 

would not likely contribute to a trend towards Federal listing or loss of viability to population or species.

Rationale for Determination

Ø There are no measurable or guaranteed impacts with implementation of Alternative 1.

Ø Alternatives 2 and 3 incorporate pileated woodpecker habitat requirements into the 

project design and mitigations. Snags will be retained unless they present an OSHA 

defined safety hazard. 

Ø Ponderosa pine where appropriate, will be retained for pileated woodpecker nesting. 

Alternatives 2 and 3 will protect ponderosa pine reducing competition and potential loss 

by fire. 

Ø Downed woody debris will be reduced but will be left in amounts within the historic 

range, which should provide sufficient foraging habitat. 

Ø Monitoring shows pileated woodpeckers are well distributed across the forest

F. Gray Wolf (Canis lupis) (Non-Essential, Experimental Population)

We have no evidence that gray wolves occurred in the area in recent decades prior to the USFWS

reintroduction near the Salmon River in January 1995. The analysis of potential impacts looks at potential 

for temporary disturbance for each of the alternatives.

Effects Analysis Methods 

Confirmed reports of tracks, scat, howling, and wolf sightings in and adjacent to the Lower West Fork 

analysis area and Forest-wide are have been documented since 2000. There are no known denning sites 

Affected Environment
Affected Environment & Environmental Consequences - Wildlife 

3.8-42 Lower West Fork Project Final EIS 

Potential Impacts to Gray Wolf

Alt. 1: No effect

Alt. 2 & 3: Not Likely to 

Jeopardize the Gray Wolf

within the analysis area, although radio-collared, transplanted wolves have been tracked on National Forest

in the analysis area. The activity is mainly transient in the analysis area with the exception of the Sula pack 

that usually occupies the Piquett Creek drainage. A possible den location for this pack, believed to be in 

the Warm Springs drainage, was burned over during the 2007 fire season. The collared wolf in that pack 

has since been located in the Chicken Creek to Little Blue Joint Creek area (Pers. comm. Bradley 2008, PFWL-017).

Following the reintroduction of gray wolves to the Northern Rockies in 1994, the Bitterroot NF was listed 

as a Non-essential Experimental Population Area for the species. Since the reintroduction, the Fish and 

Wildlife Service and Montana FWP have continued to monitor the movements and activity of gray wolves 

throughout the Northern Rockies, including activity on the Bitterroot NF. On May 4, 2009, the distinct 

population segment (DPS) of the gray wolf in the Northern Rocky Mountains (NRM) was removed from 

the Threatened and Endangered Species list, except in Wyoming (74 FR 15123). In 2009, Montana and 

Idaho held the first regulated gray wolf hunting season in history. Gray wolves are currently managed as a 

sensitive species on the Bitterroot NF.

Population estimates from 2008 indicate the NRM DPS contained approximately 1,639 gray wolves in 95 

breeding pairs. As of Dec 31, 2008, Montana contained approximately 497 wolves and 34 breeding pairs in 

84 verified packs (Montana FWP 2009). These numbers are about 5 times higher than the minimum 

population recovery goal and 3 times higher than the minimum breeding pair recovery goal (74 FR 15123). 

The end of 2008 marked the ninth consecutive year the gray wolf population exceeded numeric and 

distributional recovery goals.

Wolves are classified as habitat generalists. The entire analysis area is currently suitable habitat for wolves 

based on availability of prey species and their adaptability to utilize a variety of habitats.

Alternative 1

Direct and Indirect Effects

Since Alternative 1 prescribes no action, there would be no effect to 

gray wolves or their habitat.

Alternatives 2 and 3

Proposed activities have the potential to displace individual wolves 

from using a den or rendezvous site if one or both were to occur in the 

analysis area. The potential for displacement of individual wolves 

would be low. Ample habitat is available for wolf dispersal because 

their territories range in size from 300 to 400 square miles. 

Cumulative Effects

The Lower West Fork analysis area is the cumulative effects area for gay wolves. This is the appropriate 

area to analyze the incremental effects of the project actions on wolves in conjunction with past, present, 

and reasonably foreseeable actions. An assessment of information available at the Forest level is also 

considered to provide additional context.

Geographic Boundaries 

The newly designated wolf hunting season has relatively low quotas relative to the size of the overall wolf 

population and the number of wolf mortalities that occur each year because of livestock and other 

management conflicts. The occurrence of a hunting season will most likely effect the distribution and 

behaviors of the species; however, it probably will not jeopardize the continued existence of the species nor 

Other Actions & Trends
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-43

lead to the re-listing of the species. The wolf deaths from hunting or management conflicts would not 

combine with project effects to cause the re-listing of the gray wolf. 

The effects determination for gray wolf for all of the alternatives is ‘May impact individuals or habitat’.

Determination

G. Canada Lynx (Lynx Canadensis) (Threatened)

Potential impacts on Canada lynx habitat are analyzed for each of the alternatives. Lynx are not known or 

expected to occupy habitats in the Lower West Fork analysis area. The most recent verified lynx 

observations in the project area were recorded in the winter of 1991 (MTFWP). Lynx tracks were observed 

in Piquett Creek (T1N R21W sec 25 & 36; T1N R20W sec 31) once per month in January, February, and 

March of 1991. No lynx observations have been verified in the project area or on the West Fork Ranger 

District since then. 

Effects Analysis Methods 

The USFWS no longer lists Canada lynx as a ‘Threatened, Endangered, and Candidate species’ on the 

Bitterroot NF (DOI USFWS 2009). Lynx habitat on the Bitterroot NF is considered ‘secondary unoccupied 

habitat’. Though it is unlikely lynx are resident or transient in the Lower West Fork analysis area, the 

Forest Service assessed effects on lynx habitat following the Northern Rockies Lynx Management Direction 

Standards & Guidelines Consistency Evaluation Table for Project Specific Activities (PF-WL-002). They

also consider management direction found in Attachment 1 of the 2007 Northern Rockies Lynx 

Management Direction Record of Decision (NRLMD ROD) (USDA Forest Service 2007). 

As defined in the Lynx Conservation Assessment Strategy (LCAS), lynx habitat occurs in mesic coniferous 

forests that experience cold, snowy winters and provide a prey base of snowshoe hare. In the northern 

Rockies, lynx habitat generally occurs between 3,500 and 8,000 feet of elevation, and primarily consists of 

lodgepole pine, subalpine fir, and Engelmann spruce. Habitat may also consist of cool, moist Douglas fir, 

grand fir, western larch, and aspen when interspersed in subalpine forests. Dry forest do not provide lynx 

habitat. Lynx also require a mosaic within forest of varying stand ages and structure to support abundant 

snowshoe hares. Lynx are a highly mobile animal, moving long distances to find abundant prey, and use a 

large area on a landscape. The average home range for a male lynx is 58 square miles (LCAS). 

On the Bitterroot NF, lynx habitat has been identified following a standard mapping protocol used 

throughout the Region. Through this mapping effort, lynx habitat was divided into Lynx Analysis Units 

(LAU) as the units for which the effects of a project should be analyzed. The LAU boundaries remain 

constant and the area of each LAU ranges between 25 and 50 square miles, the average home range size of 

a female lynx. The Lower West Fork project falls across two LAUs: the Piquett-Black LAU and the RockWard LAU. The Piquett-Black LAU, on the east side of the West Fork River, is 50,414 acres containing 

10,105 acres of suitable lynx habitat. The Rock-Ward LAU, on the west side of the river, is 127,108 acres 

with 25,009 acres of lynx habitat. 

Affected Environment

Alternatives 2 and 3 have several treatment units that contain lynx habitat (Table 3.8-9). Units 32, 33, 60,

and 61A are eight percent (203 acres) of the Rock-Ward LAU lynx habitat. Units 14, 89, 92 and 93 make 

up less than 1 percent (17 acres) of the lynx habitat in the Piquett-Black LAU.

Field inspection found most of the designated lynx habitat in these units was not suitable habitat. Units 14 

and 93 were burned in the Rombo fire and as a result do not provide adequate horizontal coverage for lynx 

or their prey. Additionally, units 14 and 89 are part of a terraced plantation, which ultimately causes these 

units to be unsuitable habitat. Units 33, 60, 61A, and 89 all have large amounts of ponderosa pine and 

Douglas-fir within their boundaries, indicating these areas are too dry to provide suitable lynx habitat. 
Affected Environment & Environmental Consequences - Wildlife 

3.8-44 Lower West Fork Project Final EIS 

Potential Effects on Canada 

Lynx

Alts. 1, 2, & 3: No Effect

Table 3.8- 9: Area of Lynx Habitat within Treatment Units

Unit Total Area 

(acres)

Lynx 

Habitat

(acres)

Dominant Vegetation 

Species Treatment1 Suitability of Habitat

14 19 4 ponderosa pine NCT CT 

RX

Inadequate horizontal cover, too 

warm and dry, single species 

overstory

322 131 60 sub-alpine fir RX suitable

33 283 41 Douglas-fir/ponderosa pine RX Too warm and dry for suitable 

habitat

603 140 41 sub-alpine fir, Douglas-fir, 

ponderosa pine

NCT CT 

RX

Too warm and dry for suitable 

habitat

61A 414 62 Douglas-fir/ponderosa pine

/white bark pine RX Too warm and dry for suitable habitat

89 61 9 Douglas-fir/ponderosa pine NCT CT 

RX

Too warm and dry for suitable 

habitat

92 27 3 ponderosa pine NCT RX Douglas-fir dominant in lynx 

habitat

93 12 0.5 lodgepole pine NCT Inadequate horizontal cover 1 CT: commercial thin, NCT: non-commercial thin, RX: prescribed fire 2

Shaded rows represent units belonging to the Rock-Ward LAU, unshaded rows represent units belong to the Piquett-Black LAU. 3

Unit 60 is part of Alternative 2. In Alternative 3, this unit is dropped from treatment. All other units listed in this table are part of 

Alternatives 2 and 3. 

Direct, Indirect & Cumulative Effects

Rock-Ward and Piquett-Black LAUs are the direct, indirect, and cumulative effects analysis areas for 

Canada lynx. These areas are appropriate to analyze the project incremental effects on Canada lynx in 

conjunction with past, present, and reasonably foreseeable actions because they encompass the average 

home range of a female lynx. An assessment of information available at the Forest level is also considered 

to provide additional context.

Geographic Boundaries

Alternative 1

There are no proposed treatments in this alternative, therefore no direct, indirect, or cumulative effects will 

occur to Canada lynx or their habitat.

Alternatives 2 & 3

The treatments proposed in Alternatives 2 and 3 would treat 

approximately 220 and 179 acres of lynx habitat, respectively. These 

treatments would occur on less than 1 percent of the available lynx 

habitat in the two designated LAUs. 

Direct effects of treatment will be minimal on lynx habitat because of the small amount of suitable habitat 

that would be treated and the type of treatment planned. All treatments adhere to standards and guidelines 

put forth in Attachment 1 of the NRLMD for vegetation management activities in the WUI. Minimal 

amounts of lynx and snowshoe hare habitat will be altered during the prescribed burning; however the 

ultimate effect of this treatment will be the creation of multi-storied habitats which would provide more 

suitable habitat over the long-term. Any potential lynx in the treatment areas may be temporarily 

displaced; however this seems unlikely due to the lack of lynx in the analysis area as well as the time of 

year that the treatments would take place. Lynx would most likely be at higher elevations while the 

treatments are occurring and would not be bothered by the activities. 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-45

Indirectly, the treatments would most likely not have a negative impact on the available lynx habitat. The 

treatments would reduce fuel and lessen the likelihood of high severity wildfire occurring. Stand replacing 

fires are one of the major threats to lynx habitat and their prey since these types of fires eliminate all hiding 

and foraging cover. 

On a landscape level, the Trapper-Bunkhouse project, the Rombo fire, and the fires in 2000 must be 

considered with the Lower West Fork analysis. The fires in 2000 burned through a large amount of 

potential lynx habitat, but now, 10 years later, the forest is regenerating into stages that support lynx and 

their prey. The Rombo fire eliminated lynx habitat in higher elevations, but will grow into suitable habitat 

in 10-30 years. The Trapper-Bunkhouse project was determined to have no effect on lynx and the 

cumulative effect of that project with this current project will also be no effect. Because treatments would 

occur on a very small portion of the available habitat, in less than ideal habitat, and lynx are most likely not 

present, there would be no cumulative effects. 

The effects determination for lynx in all of the alternatives is No Effect.

Determination

H. Bald Eagle (Haliaeetus leucocephalus) (Sensitive)

The analysis of potential impacts on bald eagles looks at potential for temporary disturbance for each of the 

alternatives.

Effects Analysis Methods 

Bald eagles were removed from Federal listing as a Threatened species on August 8, 2007 (PF-WL-018). 

The bald eagle was added to the Regional Forester’s Sensitive Species List when it was removed from 

Federal listing (PF-WL-019).

Affected Environment

Bald eagles are not known to nest in the Lower West Fork analysis area. Bald eagle nesting or roosting 

habitat typically includes mature to over-mature mixed conifer, ponderosa pine and cottonwood stands near

large rivers or lakes. No suitable bald eagle nesting habitat exists within the analysis area, however, bald 

eagles occasionally pass through the area during migration and forage along the West Fork River during 

winter. It is possible that bald eagles wintering along the West Fork could use mature dense forest types 

for night roosts under certain weather conditions. 

Direct, Indirect & Cumulative Effects

The defined direct, indirect, and cumulative effects area for bald eagles is the West Fork River corridor that 

bisects the Lower West Fork analysis area. This area is appropriate to analyze the incremental effects of 

this project on bald eagles in conjunction with past, present, and reasonably foreseeable actions. An 

assessment of information available at the Forest level is also considered to provide additional context.

Geographic Boundaries 

All Alternatives

None of the proposed treatment units is within any of the Nest Site Management Zones (USDI Bureau of 

Reclamation 1994). Therefore, none of the alternatives has potential to disturb bald eagles in these zones. 

None of the alternatives would affect suitable bald eagle nesting, roosting or foraging habitat. Since the 

alternatives would not cause any direct or indirect effects to bald eagles, there would be no cumulative 

effects.

The effects determination for bald eagles under all of the alternatives is ‘No Impact’.

Determination
Affected Environment & Environmental Consequences - Wildlife 

3.8-46 Lower West Fork Project Final EIS 

Potential Impacts to Western 

Big-Eared Bat

Alt 1: No impact

Alt 2 & 3: May impact 

individuals or habitat, not

likely to affect population 

viability

I. Western Big-Eared Bat (Plecotus townsendii) (Sensitive)

There are no known primary western big-eared bat (also known as Townsend’s big-eared bat) habitats,

such as caves or mines, in the analysis area so effects on snags as temporary refugia are assessed for each 

alternative.

Effects Analysis Methods 

The Bitterroot NF is within the range of the western big-eared bat. Hoffman et al. (1969) collected 

specimens northeast of Florence, at the Curlew Mine, in Hamilton, and at Lake Como. The bats use a wide 

variety of vegetation types, from juniper/pine to high elevation mixed conifer forests (Barbour and Davis 

1969). Caves and abandoned mines are used for maternity roosts and hibernacula (Foresman 2001). 

Females form maternity colonies in spring and summer, where they bear and raise young in colonies of 20 

to 180 females (Pearson et al. 1952). Males are more solitary, may forage further into the forest, and 

occasionally roost in tree cavities or behind loose bark. In late summer, these bats may roost in buildings. 

Caves or mine tunnels are essential to western big-eared bat nursery and hibernating colonies. None of the

known caves or tunnels within the analysis area would be suitable for a nursery or hibernating colony. 

Affected Environment

Direct, Indirect & Cumulative Effects 

The direct, indirect, and cumulative effects area for big-eared bats 

is the Lower West Fork analysis area. This area is appropriate to 

analyze the project effects on big-eared bats in conjunction with 

past, present, ongoing and reasonably foreseeable actions. 

Geographic Boundaries

Alternative 1

There are no proposed treatments in this alternative, therefore no 

direct, indirect, or cumulative effects will occur.

Alternatives 2 and 3

Alternatives 2 and 3 would have the same effects on western big-eared bats though less area is treated 

under Alternative 3. No caves or tunnels exist in the treatment units that would be suitable for a western 

big-eared bat colony. These bats are not snag dependent; however, given the increase in snags spread over 

the landscape, there is a possibility that they will use tree cavities or loose bark as temporary roosts. These 

roosts are usually used in passing and primarily for refugia from weather events. The removal of trees with 

potential to be used as refugia may impact individual western big-eared bats but would be of low incidence 

considering that there are no known primary habitats within the analysis area. Because caves, tunnels, and 

occasional abandoned buildings are critical habitats and because there are none in the analysis area, none of 

the proposed activities would affect western big-eared bat habitat or their viability. 

Alternative 1 (No Action)

Determination

Implementation of this alternative would have no impact on western big-eared bats or their habitat.

Alternative 2 and Alternative 3

Implementation of Alternative 2 or 3 may impact individual western big-eared bats or their habitat, but 

would not likely contribute to a trend towards Federal listing or loss of viability to population or species.

Rationale for Determination

Some snags would be removed which could potentially be used as a temporary refugia.
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-47

J. Wolverine (Gulo gulo) (Sensitive)

The potential of project activities to disturb wolverines by is analyzed for each alternative.

Effects Analysis Methods & Reference Conditions 

Wolverines are solitary animals and range widely over a variety of habitats. Isolation from human impacts 

and a diverse prey base seem to be the most important habitat components. Within large roadless areas, 

such as the Selway-Bitterroot Wilderness that borders the project area to the west, wolverine use appears to 

be concentrated in medium to scattered mature timber and in ecotonal areas around natural openings such 

as cliffs, slides, basins, and meadows. There seems to be little use in stands of dense young timber or in 

openings such as clearcuts or wet meadows (Reel et al. 1989; Butts 1992).

The wolverine is an uncommon inhabitant of boreal coniferous forests and arctic tundra (Copeland 1996). 

Wolverines use a variety of habitats, but appear to do best in relatively undisturbed, remote mountainous 

areas. Wolverine habitat is probably best defined in terms of adequate year-round food supplies in large, 

sparsely inhabited wilderness areas, rather than in terms of particular types of topography or plant 

associations (Lofroth 1997). However, Hornocker and Hash (1981) found that wolverines tended to select 

true fir cover types throughout the year in their study area in northwest Montana, while wolverines in 

central Idaho avoided lowland grass or shrub and ponderosa pine cover types (Copeland 1996). 

Wolverines feed primarily on rodents and carrion, though as opportunists they will consume berries, 

insects, fish, birds, and eggs when available. Ungulate carrion seems to be particularly important in the 

winter; and wolverine may move to lower elevations during winter to take advantage of dead ungulates on 

winter ranges (Copeland 1996, Butts 1992, Reel et al. 1989). 

Wolverine home ranges are very large, averaging approximately 150 square miles for females and 163 

square miles for males in a study in northwest Montana (Hornocker and Hash 1981), and 142 square miles 

for females and 611 square miles for males in a study in central Idaho (Copeland 1996). Hornocker and 

Hash (1981) found that individual home ranges in Montana overlapped regardless of sex, and territorial 

defense was essentially nonexistent. This observation may have been caused by consistent harvest of 

individuals in their study area. Conversely, Copeland (1996) found that adult home ranges in an area with 

very limited wolverine harvest were segregated by sex with little overlap between individuals of the same 

sex. However, male home ranges encompassed up to three female home ranges. 

With few exceptions, wolverine reproductive dens have been located in alpine, subalpine, taiga, or tundra 

habitats (Magoun and Copeland 1998 including extensive internal citations). In Idaho, wolverine dens 

occurred in snow-covered, boulder talus, subalpine cirque basins. They were located at high elevations and 

consisted of long, complex snow tunnels under inaccessible boulder scree that provided a high degree of 

security. A critical feature of wolverine denning habitat appears to be dependability of deep snow 

throughout the denning period (February through April). Almost all verified reproductive dens were 

beneath 1-5 meters of snow. 

Suitable wolverine denning habitat exists in the higher basins in all the large drainages within the 

Wilderness, well outside of the project area and proposed treatments. The project area contains little, if 

any, habitat that meets wolverine denning habitat criteria and no denning sites are known to occur within it. 

Wolverines in Montana display a distinct seasonal elevational movement pattern. In the summer, they 

move to higher elevations and inhabit forests dominated by subalpine fir. Upper elevations within the 

project area are probably suitable summer wolverine habitat to some degree, although better habitat occurs 

mostly in the moister forests west of the project area. Wolverines could utilize the lower portions of the 

project area, especially when searching for carrion during the winter (Reel et al. 1989, Butts 1992). For 

this reason, low elevation riparian areas may be important in the winter (Reel et al. 1989, Butts 1992). 

Wolves from the Sula pack are also present in lower elevations of the project area during the winter, and 

may compete with wolverines for carrion or prey on wolverines.

Affected Environment
Affected Environment & Environmental Consequences - Wildlife 

3.8-48 Lower West Fork Project Final EIS 

Potential Impacts to 

Wolverine

Alt 1: No impact

Alt 2 & 3: May impact 

individuals, not likely 

to affect population 

viability

In the past several years, the Forest Service has recorded wolverines on the Bitterroot NF, though none 

were reported in the proposed treatment areas. No tracks have been noted on pine marten survey routes on 

the West Fork Ranger District except in 2004. These tracks were not located in the analysis area. 

According to Montana FWP trapping records, only six wolverines have been trapped in the Bitterroot 

Valley since 1980, the last one in 2002. If wolverines occur in the analysis area, they are probably transient 

individuals. This area is not considered wolverine habitat because it is well roaded and has considerable 

historical timber management. 

Direct, Indirect & Cumulative Effects

The direct, indirect, and cumulative effects area for wolverine is the Lower West Fork analysis area. This 

area is appropriate to analyze the incremental effects of this project on wolverine in conjunction with past, 

present, and reasonably foreseeable actions. 

Geographic Boundaries

Wolverines are considered transient because of their large home ranges

and the absence of denning habitat in proposed treatment areas. 

Therefore, the potential to disturb wolverines would be low. Individuals

could be displaced if they pass through this area looking for winter range 

carrion. However, they would have ample area remaining in their vast 

home range to avoid any activities associated with the alternatives. None 

of the proposed actions would affect wolverine habitat or species viability 

because the principal big game prey base would remain stable or increase. 

Since there would be no effects from this project on wolverine, there 

would be no cumulative effects on them or their habitat.

All Alternatives

Alternative 1(No Action)

Determination

Implementation of this alternative would have no impact on wolverine or their habitat.

Alternative 2 and Alternative 3

Implementation of Alternatives 2 or 3 may impact individual wolverines or their habitat, but would not 

likely contribute to a trend towards Federal listing or loss of viability to population or species.

Rationale for Determination

There are no measurable impacts with implementation of Alternative 1.

The project area does not provide wolverine habitat because it is well roaded and has considerable 

historical timber management. Individuals may wander into the area looking for carrion in the winter. If 

this occurs during project activity, the individual could be displaced. There would be ample area remaining 

in their home range to which they could be displaced.

K. Boreal Toad (Bufo boreas) (Sensitive)

The analysis of boreal toads focuses on activities that could cause direct or indirect mortality in riparian 

habitats. We have selected this criterion to analyze effects on boreal toads because of the importance of 

riparian areas to boreal toads. 

Effects Analysis Method & Reference Conditions

Boreal toads are found in a variety of habitats from valley bottoms to high elevations. They breed, 

reproduce, and develop to maturity in still water (lentic) lakes, ponds, and slow streams and prefer shallow 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-49

Potential Impacts to Boreal Toads

Alt. 1: No impact

Alt. 2 & 3: May impact 

individuals or habitat, not 

likely to affect population 

viability.

areas with mud bottoms. Adult boreal toads are “largely terrestrial,” except during the breeding season, 

and occur along the edges of rivers and streams. Terrestrial activity is physiologically restricted by water 

balance and thermoregulation requirements (Sinsch 1990 IN Adams et al. 2005, p. 31). Boreal toads were 

found at 16 sites in a 1995 Bitterroot NF survey (Hendricks and Reichel 1996). 

Adams et al. (2005 pg. 28) noted that several studies indicate boreal toads sometimes make seasonal 

migrations of 0.9–2.4 kilometers but their summer home range movements are considerably shorter. 

Adams et al. (2005, p. 30) found that boreal toads made extensive instream movements in their study on 

streams of the West Fork River. During mid-summer, they detected movements up to 500 meters per day. 

No previous publications documented long distance water travel. During the breeding season, adults are 

found in water and in nearby upland habitats (Hendricks and Reichel 1996). Adult toads may migrate to 

over-wintering chambers associated with streams or spring seeps, and commonly, rodent burrows deep 

enough to prevent freezing and with soil moisture high enough to prevent desiccation (PF-WL-020). 

Inventories conducted in 2001 through 2003 showed no evidence of boreal toads in the lower West Fork 

analysis area (Maxell 2004), though there is reliable, anecdotal information suggesting boreal toad are 

present in the analysis area. The entire project area provides boreal toad suitable habitat given their use of 

a variety of habitats, although use may be limited in the denser stands on north-facing slopes (Bull 2006).

Affected Environment

Alternative 1

Direct & Indirect Effects

There are no proposed treatments in this alternative, therefore no 

direct, indirect, or cumulative effects would occur.

Alternative 2

In Alternative 2, a maximum of 300 acres would be sprayed 

annually with herbicides in the Lower West Fork analysis area, for 

a period of 10 years. Spraying would focus on high risk areas of 

weed spread such as haul roads, skid trails, log landings, temporary roads, decommissioned and stored 

roads, and portions of prescribed fire units. Spraying would either occur by truck or by hand (i.e. 

backpack). There would be no aerial spraying. The mitigation measures for herbicide spraying are listed in 

Chapter 2. Mitigation measures that protect aquatic resources during herbicide applications (FEIS pg. 2-

21) are highly effective and discussed in Table 3.7-4 of the Fisheries section. 

Information about pesticides effects on amphibian populations is limited, and the studies that are available 

often focus on the most toxic compounds like insecticides; consequently, this risk analysis relies heavily on 

inference from the available published studies. This risk analysis also tiers to the Selway-Bitterroot 

Wilderness Invasive Plants Management Project Draft Environmental Impact Statement (SBW Weeds 

DEIS) (USDA Forest Service 2008d) and much of the information in this risk analysis is summarized from

the more detailed information in the SBW Weeds DEIS.

To date, atrazine is the only herbicide active ingredient that has been implicated in overall amphibian 

declines (USDA Forest Service 2008d, pg. 24). This herbicide is not proposed for use in this project. 

Relyea (2005) implicates the glyphosate formulation, Roundup, in amphibian decline, but the formulation 

studied contains a surfactant known to be toxic to aquatic organisms. Numerous previous studies have 

attributed the toxicity of this formulation to the surfactant and not the glyphosate active ingredient (e.g. 

Mann and Bidwell 1999; Perkins et al. 2000). Since Relyea (2005) did not report results for the aquatic 

formulation of glyphosate that does not contain the toxic surfactant, his study results cannot be attributed to 

the herbicide. 
Affected Environment & Environmental Consequences - Wildlife 

3.8-50 Lower West Fork Project Final EIS 

The pesticides investigated (e.g. carbaryl, PCBs, atrazine) all have much higher propensity to accumulate in 

fatty tissues than the herbicides proposed in this document. There is a data gap on the effects herbicides 

proposed in this analysis may have on amphibian populations. Current data on these herbicides do not 

suggest a risk to amphibian populations because the herbicides do not accumulate in animal tissues and are 

less persistent, less mobile, and less widely used than pesticides that have been implicated in amphibian 

declines.

Project design criteria respond to the uncertainty about effects of herbicide exposure on amphibians. The

project design criteria include buffers that prohibit broadcast spraying, specify selective application 

methods, and limit the types of herbicides that can be used within certain distances of amphibian habitat

(Ch.2 pg. 2-21). Herbicides proposed for use in the project area have little potential to adversely affect 

amphibians and contribute to amphibian decline because of their low toxicity and the very low exposures 

likely to occur. The herbicide application rates and physical properties, and the use restrictions included in 

the design criteria would minimize amphibian exposures.

Most of the herbicides proposed for use in the project pose a low mortality risk in amphibians, including 

chlorsulfuron, clopyralid, imazapic, metsulfuron methyl, and picloram. Data is unavailable to evaluate risk 

from Dicamba, Imazapic, 2,4-D, and Curtail, but we assume that risks would be similar to those evaluated 

for the fisheries resource. However, formulations of glyphosate that contain POEA surfactant, e.g., 

Roundup, are much more toxic to aquatic organisms than aquatic-labeled formulations, which do not 

contain POEA. Project design criteria prohibit the use of glyphosate with POEA surfactant in RHCAs, or 

within 100 feet of stream, lake, or wetland habitats. These measures make it highly unlikely that this 

formulation of glyphosate would reach water bodies or concentrate enough to negatively affect amphibians. 

As adult amphibians move through treated vegetation or soil, they could be exposed to herbicides through 

their skins. Since most amphibians are predominantly aquatic, this type of exposure would be unlikely. 

However, boreal toads may have a higher risk of exposure because they travel greater distances from water. 

There is insufficient data to quantify dose received from dermal exposure of contaminated vegetation or 

soil, but it is likely to be much less than if the amphibian was in contaminated water and could easily 

absorb the solution through its skin. We assume in this analysis that risk from exposure to contaminated 

water adequately encompasses risk from other types of herbicide exposure. 

There is a low likelihood of disturbance to amphibian eggs, larvae, or adults during invasive plant 

treatments, although some disturbance could occur to adults moving overland. Adverse effects from 

herbicide exposure are unlikely because of the relatively low toxicity of most herbicides proposed, the low 

concentrations in water that would occur under normal operations (i.e. low exposures), and the design 

criteria that restrict herbicide use in or near amphibian habitat. 

Individual boreal toads may be affected when crossing roads or in front of operating equipment as they 

disperse from areas containing water to upland habitats. Under the Inland Native Fish Strategy guidelines 

concerning riparian habitat conservation, areas will be buffered within 300 feet of fish bearing streams, 150 

feet near perennial non-fish streams, 100 feet near intermittent streams, 100 feet near wetlands less than 

one acre in size, 150 feet in wetlands greater than one acre, and 100 feet near landslide prone areas. These 

mitigation measures would adequately protect boreal toads and their habitat, including breeding areas, 

nursery areas, streamside over-wintering hibernacula, and travel ways. The proposed actions would not 

affect boreal toad habitat or species viability because breeding and foraging sites would be excluded from 

treatment.

Alternative 3

Invasive plants would not be sprayed with herbicides under Alternative 3 so there would be no herbicide 

effects on boreal toads from this project. The effects of unit treatments would be the same as in Alternative

2, in which individuals passing through active treatment areas may killed, but it would not likely contribute 

to a trend towards Federal listing or loss of species viability. 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-51

The Lower West Fork analysis area is the cumulative effects analysis area for the boreal toad. The size of 

this analysis area is reasonable because boreal toad movements and adult home ranges extend

approximately 440 yards to at least 1,750 yards from breeding sites (PF-WL-021). A regional assessment 

of population trends is also considered to provide additional context.

Cumulative Effects

Past timber harvest, road construction and maintenance, roadside herbicide spraying, grazing, fire fighting,

and fire suppression may have affected boreal toads or habitat in the Lower West Fork area, but whether 

impacts have occurred or their extent is not known. The boreal toad populations are declining regionally. 

Maxwell (2004, p. 7) reported that boreal toads were still widespread in the region; they were detected in 

50 percent of watersheds, and breeding in 17 percent of watersheds. Boreal toads were detected in 5.5

percent of the wet lentic sites surveyed and were breeding in 2.8 percent of the sites (Maxwell 2004). 

Surveys of more than 2000 water bodies in western Montana since 1997 have found breeding populations 

in less than 5 percent of the sites (PF-WL-022 – Steve Corn). According to historic accounts, boreal toads

were once common or abundant. Historic evidence of boreal toad breeding on the Bitterroot NF has been

reported on 16 lentic sites since 1939. Monitoring these sites and adjacent water bodies started in 2001. 

Thirteen of these localities had breeding activity in 2001-2003, 1 site had been destroyed, and 2 sites were 

unlikely to have ever supported breeding. Several of the 13 localities with breeding activity are in close 

proximity creating eight breeding clusters on the Bitterroot NF. None of the breeding clusters is in the 

Lower West Fork analysis area so the proposed project would have no cumulative effects on them 

(Maxwell 2005, p. 29).

Researchers do not know what is causing the decline, and are investigating several possible causes. 

Declines in national parks and wilderness areas, however, indicate that direct anthropogenic influences are 

not likely causing the decline (PF-WL-023). Possible causes include: acid precipitation, ultraviolet light,

and a fungus, Batrachochytrium dendrobatidis. This fungus is a pathogenic, chytrid fungus found in boreal 

toads collected at the Elk Refuge in Jackson, Wyoming. To date, it has not been detected in Montana 

(Maxwell 2004).

Recent evidence from Glacier National Park has linked boreal toads with wildfire. Some researchers are 

investigating whether forest encroachment into meadows, facilitated by fire suppression and cessation of 

cattle grazing, reduced the suitability of former breeding sites of another species of frog (PF-WL-022). The 

relationship between forest structure and boreal toad habitat is not understood well enough to predict how 

the changes in forest structure, mimicking natural densities and species composition, would influence 

boreal toads.

Alternative 1 (No Action)

Determination

Implementation of this alternative would have no impact on boreal toad or their habitat.

Alternative 2 and Alternative 3

Implementation of Alternative 2 or 3 may impact individual boreal toads or their habitat, but would not 

likely contribute to a trend towards Federal listing or loss of viability to population or species.

Rationale for Determination

Ø There are no measurable impacts with implementation of Alternative 1.

Ø Full protection of wetlands and riparian areas, through INFISH protections along with 

mitigations as incorporated by reference in the SBW Weeds DEIS (USDA Forest 

Service, 2008c will minimize impacts on breeding, nursery, streamside over-wintering 

hibernacula, and travel ways. 
Affected Environment & Environmental Consequences - Wildlife 

3.8-52 Lower West Fork Project Final EIS 

Ø Migrating individuals may be vulnerable to road maintenance, temporary road 

construction, and road decommissioning, as well as, ground activities associated with 

vegetation and fuel management. 

Ø Any individual mortality would be infrequent and not expected to affect boreal toad 

population levels.

L. Flammulated Owl (Otus flammeolus) (Sensitive)

The analysis of flammulated owls focuses on the suitable and potential habitat within the Lower West Fork 

analysis area. Potential habitat in the Lower West Fork analysis area is inclusively defined as young, seral 

ponderosa pine or Douglas-fir forests in habitat type groups A, B, C, and G. These forests may not 

currently provide flammulated owl habitat but have the potential to develop into suitable habitat. 

Effects Analysis Method & Reference Conditions

Suitable habitat currently has the components and forest structure necessary to meet the needs of 

flammulated owls. Suitable habitat has the same features as potential habitat except it is a more mature 

seral stage (mature sawtimber, multi-storied, or old growth habitat).

The wildlife biologist with knowledge of flammulated owl habitat requirements and familiar with the 

Lower West Fork analysis area reviewed and verified potential and suitable habitat mapped through a query 

of the TSMRS/FACTS database (PF-WL-024). 

Evaluation criteria used to predict impacts on flammulated owls for each alternative are: 

Ø stand structure, composition, and density of potential and suitable habitat

Ø snag density of potential and suitable habitat 

Ø temporary disturbance in suitable habitat

Based on current literature, flammulated owls are dependent on mature to old growth ponderosa 

pine/Douglas-fir forests at lower elevations in the Rocky Mountains. These habitats correspond very 

closely to habitat type groups A & B and the warmer/drier portions of habitat type groups C & G on the 

Bitterroot NF. They are found in mature, open, park-like stands with some understory shrubs and small 

trees (McCallum 1994). In general, flammulated owls nest in relatively large trees in relatively open areas. 

They are not typically associated with burned areas or extensive areas of beetle-killed trees; these areas 

probably lack physical and biological components that support both the owls and their prey. Flammulated 

owls evolved in an ecosystem primarily shaped by frequent, low intensity fires. Fire suppression changed 

many open pine forests to more shade-tolerant fir forests with dense understories of small diameter trees. 

Overall, “fire suppression may create sub-optimal habitat for flammulated owls” (Linkhart 2001, page 

168). Samson (2005) noted that virtually every author studying flammulated owls suggests fire suppression 

has had a negative influence on habitat and this is evident in the Lower West Fork area. He notes that 

mechanical removal of understory, particularly in relatively large areas, may serve as an effective 

alternative to fire. 

Stand Structure, Composition, and Density

Prior to the fires in 2000, Wright (1996) conducted a two-year study of flammulated owls on the Bitterroot 

NF. She recorded approximately 100 flammulated owl observations using a “callback survey.” Ninety 

percent of these observations were clustered (more than three owls per transect). Wright (1996) suggested 

the clustering is probably a consequence of owls occupying appropriate microhabitat only when the larger 

area is also suitable. Scientists suggest that potential habitat is suitable only when it is abundant enough to 

accommodate a cluster of territories (Montana Bird Conservation Plan 2000).

Flammulated owls appear to favor foraging in old ponderosa pine or ponderosa pine and Douglas-fir 

forests. Old ponderosa pine forests, whether pure or mixed with other species, is typically open stands with 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-53

Alternative 1 ~ Potential Impacts to 

Flammulated Owl

No impact

If high intensity fire occurs, likely reduction 

in habitat

well-developed grass or shrub understories. These understories support arthropods that fledged owlets and 

molting adults forage on extensively in late summer (Reynolds and Linkhart 1987b).

Flammulated owls prey primarily on noctuid (night flying) moths in the early spring and crickets, 

grasshoppers, moths, beetles, and other assorted bugs in the summer (McCallum 1994). The openness of 

these stands provides space for “hawking” flying insects between tree crowns and hover-gleaning from 

outer needle bunches (Reynolds and Linkhart 1987b).

Male owls sing from ponderosa pine and Douglas-fir trees with a mean age of 289 years, hidden next to the 

tree trunks or in dense clumps of foliage (Reynolds and Linkhart 1987b). Regenerating Douglas-fir 

thickets and large-diameter trees with heavy branching provide security cover for both foraging and 

roosting owls (van Woudenberg 1992, McCallum 1994b IN van Woudenberg 1999, pg. 7). 

Ponderosa pine appears to be the preferred nest tree (McCallum 1994 IN van Woudenberg 1999). Wright 

(1996) found that flammulated owl occurrence correlates with the number of ponderosa pine trees greater 

than 15 inches DBH and mean basal area of 116 ft2

/acre.

Flammulated owls depend on woodpeckers to create nesting cavities, usually in large, dead trees. Reynolds 

and Linkhart (1992) cite reports where forests surrounding nests were described or photographed and 

observe that all nests were in, or adjacent to, mature or old growth stands. However, Hasenyager et al. 

(1979) and Bloom (1983) reported nests in forests that had been partially cut but still contained large, 

residual trees, and Winter (1994) found owls in second-growth forests, though he did not report nesting in 

this age-class (Reynolds and Linkhart 1987b). 

Snag Density

Flammulated owls appear to be tolerant of humans, and are known to nest close to occupied areas 

(Hayward and Verner 1994). The effects of mechanical disturbance are unknown and harvesting or 

thinning during the nesting season might cause nest abandonment.

Temporary Disturbance

There are approximately 2,250 acres of potential flammulated owl habitat and 10,100 acres of suitable 

habitat in the Lower West Fork analysis area. The suitable habitat quality may range from poor to fair 

based on site-specific stand characteristics such as canopy cover, small tree density, and the presence or 

absence of desirable shrubs or grasses. Fire suppression and past timber management has led to an 

uncharacteristically high percentage of mature Douglas-fir in the Lower West Fork analysis area and across 

the Bitterroot NF.

Affected Environment

From Wright’s 1996 study, only one record out of 100 flammulated observations was located within the 

Lower West Fork analysis area. This location is on private land on the lower end of the Piquett Creek 

drainage. There are clusters of locations to the north of the Lower West Fork analysis area and several 

more clusters located within the adjacent Trapper Bunkhouse project. Forest Service employees conducted 

flammulated owl surveys in several drainages of the Lower West Fork analysis area but found no 

flammulated owl locations.

Alternative 1

Direct and Indirect Effects

The No Action Alternative would not change existing 

habitat quality of flammulated owls in the short term

because forest structure and composition would not 

change. Over time, habitat quality for flammulated owls 

would decline as Douglas-fir and grand fir continue to 
Affected Environment & Environmental Consequences - Wildlife 

3.8-54 Lower West Fork Project Final EIS 

Alternative 2 ~ Potential Impacts to 

Flammulated Owl

May impact individuals or their habitat, 

not likely to impact population 

viability

Improvement to habitat composition, and 

structure for flammulated owls on 

approximately 690 acres of potential 

and 2,772 acres of suitable habitat

Temporary displacement of individuals 

possible 

regenerate in the understory of mature and old growth ponderosa pine and stand density increased. The 

open stand structure that attracts flammulated owl prey and allows the owls to forage would become 

increasingly less common. As forests continue to mature, snag numbers would increase and coarse woody 

debris would accumulate. In the longer term, increasing tree densities and fuel loads would increase the 

probability of large, intense fires. Large fires that burn with moderate or high intensities would create 

marginal or unsuitable flammulated owl habitat. 

Alternative 2

Alternative 2 proposes treatment on approximately 690 acres (31%) of potential habitat and 2,772 acres 

(27%) of suitable habitat in the analysis area. 

Alternative 2 would promote ponderosa pine and, to a lesser extent, Douglas-fir growth on approximately 

3,462 acres of potential or suitable habitat. Promoting ponderosa pine and Douglas-fir by retaining the 

large, mature stand component would immediately benefit flammulated owl habitat by retaining potential 

nest and roosting trees and opening the canopy thereby improving foraging habitat. 

Stand Structure, Composition, and Density

Approximately 271 acres of old growth habitat would be 

treated in Alternative 2, as discussed in the old growth 

section 3.8.5A (portions of units 4, 8, 9, 15, 33, 60a, 61a, 70, 

and 71). The prescriptions would reduce fuels and the risk 

of fire. Four of the nine units would be commercially 

thinned followed by prescribed fire. Some of the noncommercial, understory fuels may also be removed to control

the fire intensity. Old growth characteristics, where they 

exist at the time of treatment, would be retained after 

treatments. A certified silviculturist, in consultation with the 

fuels specialist and wildlife biologist, would write the stand 

prescriptions to retain old growth habitat characteristics and 

the silviculturist or wildlife biologist would monitor the 

treatments to assure the application of the prescription and 

retention of old growth habitat characteristics (See Section 

2.5). These treatments would reduce the risk of losing large, potential nest trees to fire in old growth 

habitat. The effects of individual treatments in old growth flammulated owl habitat are discussed below; 

units with old growth are in bold font. 

Units 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 12, 13, 14, 15,16, 18, 19, 20, 21, 22, 23, 24, 25, 26, 28, 29, 34, 35, 40, 41, 

42, 60, 61, 62, 68, 86, 88, 89, 90, and 99 would be commercially thinned and followed with a prescribed 

fire. Commercial thinning with burning would occur on approximately 564 acres of flammulated owl 

potential habitat and 1,818 acres of suitable habitat. Commercial thinning would open stand canopy but

retain dominant trees in the overstory. Prescribed fire would reduce excess fuels in the understory and 

create sites for regenerating ponderosa pine and, to a lesser extent, Douglas-fir. Opening the stand and 

retaining the large and mature stand component would improve foraging conditions and maintain nesting 

habitat. Dense tree clumps, potentially be used for roosting, would be reduced but roosting habitat would 

be available as the remaining trees respond to decreased competition and improved nutrient availability 

following the prescribed fire, or in untreated areas. The improved tree vigor and resilience to insects and 

fire would promote more stable flammulated owl habitat conditions. 

Non-commercial thinning in units 27, 75, 80, 83, 84, 85, 87, 91, 92, 94, 95, 96, 97, and 102 is designed to 

accelerate the growth, form, and vigor of the developing stands. This treatment is usually applied to young, 

crowded stands. The proposed treatments will hasten the development of suitable flammulated owl habitat 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-55

Alternative 3 ~ Potential Impacts to Flammulated 

Owl

May impact individuals or their habitat, not likely to 

impact population viability

Improvement in flammulated owl habitat 

composition, and structure on approximately 370 

acres of potential and 1,800 acres of suitable; 

Temporary displacement of individuals possible 

If high intensity fire occurs

Likely reduction in habitat

structure. Non-commercial thinning would occur on approximately seven acres of flammulated owl 

suitable habitat and 108 acres of potential habitat.

Prescribed fire would be used in Units 32, 33, 60A, 61A, 64, 63, 63B 65, 66, 69, 70, 71, 72, 73, 74, and 100 

to reduce fuels and maintain or enhance the mature and old growth habitats. These units contain 

approximately 18 acres of potential flammulated owl habitat and 947 acres of suitable habitat. Reducing 

fuels in these units reduces the risk of stand replacing fires, which would retain structural stand components 

important to flammulated owls and their habitat.

Stand treatments would not remove snags unless they create an OSHA defined safety hazard. Existing

snags would be retained for potential nesting sites and large, ponderosa pine will be favored for future snag 

development. 

Snags

Flammulated owls are not currently known to occupy any proposed treatment units. 2,772 acres of suitable 

habitat are proposed for treatment. If the treatment areas are occupied and treatments occurred during the 

nesting season, individual owls may be temporarily displaced. Since flammulated owls are migratory, any 

activity occurring from September through April would not affect their distribution. No effect on species 

viability is expected. Vegetation removal using prescribed fire or mechanical treatments could cause an 

indirect effect of decreasing insect populations and flammulated owl foraging opportunities. This would be 

a short-term effect lasting 1-2 years until the area re-vegetates and trees respond to improved growing 

conditions. The insect populations would correspondingly increase with improving vegetation conditions. 

Temporary Disturbance

Alternative 3

Alternative 3 proposes treatment in approximately 435 acres (19%) of potential habitat and approximately 

1,810 acres (18%) of suitable habitat. Approximately 237 acres of old growth habitat (highlighted in bold

font below) would be treated, as discussed in the old growth section 3.8.5A. 

Alternative 3 proposes treatment on approximately 

63 percent of ponderosa pine/Douglas-fir habitats 

as proposed in Alternative 2 and therefore the 

effects are considered to be nearly negligible. 

Future fires, when and where they occur, are more 

likely to jeopardize those areas not treated on the 

east side of the West Fork River. 

Stand Structure, Composition, and Density

Units 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 14, 21, 25,

34, 35, 61, 62, 86, 88, 89, 90, and 99 would be 

commercially thinned and followed with prescribed 

fire. Units 27, 75, 80, 82, 83, 84, 87, 91, 92, 94-97, 

and 102 would be non-commercially thinned. 

Approximately 1,284 acres of commercial harvest 

are in flammulated owl suitable habitat and 317

acres are in potential habitat. The non-commercial thin treatments affect the same areas as in Alternative 2. 

The treatments and effects on flammulated owl habitat are the same as described in Alternative 2; however 

slightly less area is proposed for commercial thinning. 

Units 32, 33, 60a, 61a, 63, 63b, 70 and 100 would be treated with prescribed fire. Approximately 11 acres 

are potential flammulated owl habitat and 518 acres are suitable habitat. The treatments and effects on 

habitat are the same as described in Alternative 2; however slightly less area is proposed for treatments. 
Affected Environment & Environmental Consequences - Wildlife 

3.8-56 Lower West Fork Project Final EIS 

Stand treatments would not remove snags unless they create and OSHA defined safety hazard. Existing 

snags would be retained for potential nesting sites and large, ponderosa pine will be favored for future snag 

development. 

Snags

About 1,810 acres of suitable habitat would be treated under this alternative. As in Alternative 2,

flammulated owls may be temporarily displaced if they are present during the proposed activities and 

foraging opportunities may decrease for 1-2 years if insect populations decline following treatment.

Temporary Disturbance

Geographic Boundaries and Time Period

Cumulative Effects

The cumulative effects analysis area for flammulated owls is the Lower West Fork analysis area. This area 

is appropriate to evaluate the incremental effects of the proposed alternatives on flammulated owls and 

their habitat in conjunction with past, present, and reasonably foreseeable actions. The size of flammulated 

owl home range determined the cumulative effects analysis area. Flammulated owl home ranges vary 

between 22 and 58 acres (Samson 2005, pg. 52). Theoretically, there could be between 174 and 459 home 

ranges in the 10,100 acres of suitable habitat in the Lower West Fork analysis area. Incremental effects of 

proposed project activities on home ranges outside the analysis area would not be measurable. An

assessment of the habitat and population viability at the Forest level is also considered to provide additional 

context. 

Alternative 1 

The Trapper-Bunkhouse project, north of the Lower West Fork analysis area, would protect the 

flammulated owl habitat in that project area but would not buffer flammulated owl habitat in Lower West 

Fork because of the landform and prevailing winds. Fire typically spreads from west to east or south to 

north. Therefore, Alternative 1 may jeopardize flammulated owl habitat on the southern edge of the 

Trapper-Bunkhouse project area because fire in untreated stands would burn at higher intensities and be 

harder to contain if winds are from the south or southwest. 

The Rombo fire burned 2,980 acres of suitable flammulated owl habitat and reduced habitat in the Lower 

West Fork analysis area from 13,072 acres to 10,092 acres. The Rombo fire may buffer some of the

suitable flammulated owl habitat in the southeast portion of the analysis area but most of the habitat would 

be vulnerable to fire starts in the western and southwestern parts of the analysis area (Fig. 3.3-1). From a 

landscape perspective, the Trapper-Bunkhouse and Rombo Fire do not buffer the suitable flammulated owl 

habitat from potential fires. 

Alternative 2

Reducing stand density and retaining large diameter ponderosa pine as the dominant stand component 

would improve flammulated owl habitat throughout the analysis area and across the landscape. Since 

winds typically come from the south or west, treatments in the Lower West Fork area would extend the 

habitat improvement in the Trapper-Bunkhouse project across the landscape for approximately 25 – 50 

years. 

Treatments on the east side of the West Fork River would improve flammulated owl habitat and reduce 

potential fire intensity in the treated units as well as extend the buffer created by the Rombo Fire. The 

reduced stand density would also facilitate the periodic use of low intensity fire throughout the Lower West 

Fork analysis area to maintain stand conditions favorable to flammulated owl habitat. The implementation 

of Alternative 2 would create a continuous flow of suitable and potential flammulated owl habitat.
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-57

Alternative 3

The cumulative effects of Alternative 3 would be the same as Alternative 2 on the west side of the West 

Fork River; the treatments would extend the habitat improvement from the Trapper-Bunkhouse project 

across the landscape. On the east side of the River, there would be less protection of flammulated owl 

habitat since less area would be treated. However, treatments between Violet and East Piquett Creeks 

would extend the fuel break created by the Rombo Fire, provide some buffering, and interrupt potential fire 

behavior in the event of a fire. Therefore, there would be more protection of flammulated owl habitat 

under this alternative than under Alternative 1. 

Other Actions

Flammulated owls may be vulnerable to the effects of fire suppression, which modifies forest structure, and 

composition (Groves et al. 1997; Wright et al. 1997; Linkhart 2001; and van Woudenberg 2003 IN Samson 

2005). Fire suppression in the Lower West Fork analysis area has shifted stand dominance from ponderosa 

pine to Douglas-fir, which is more shade-tolerant and out-competes ponderosa pine regeneration. This shift 

in species dominance creates stands with closed canopies and high stem density, which do not meet 

flammulated owl habitat characteristics (McCallum 1994). The structure of these stands and the high 

potential of trees dying from insects and disease before they reach maturity exacerbate the lack of nest-tree 

development. Dense stands create conditions that promote severe intensity fires in areas historically burned 

by low or mixed intensity fires. Severe intensity fires would reduce suitable habitat and could remove the 

ponderosa pine seed source, hampering ponderosa pine natural regeneration of (USDA 2000). 

Flammulated owl breeding habitat may be constrained by the lack of stable snags with suitable nest 

cavities. Past timber harvest and firewood cutting have reduced the number of snags across the forest. 

Snags would not be harvested under Alternatives 2 and 3 unless they present an OSHA defined hazard. 

Firewood cutting would continue to remove snags that may or may not be suitable nest trees. However, 

firewood cutters typically cut snags close to open roads and prefer Douglas-fir over ponderosa pine. We 

expect the loss of snags from the expansion of Douglas-fir in ponderosa pine habitats to have a greater 

negative impact on flammulated owls than the loss of appropriate snags from incidental harvest or firewood 

cutting. Van Woudenberg (1999) determined the overall loss of the ponderosa pine component and 

expansion of Douglas-fir stands may have long-term consequences for the abundance of breeding owls by 

reducing the quantity of suitable cavity trees for nesting. 

Trends

Fire suppression has had a substantial effect on flammulated owl habitat (Sampson 2005). The existing 

trend in flammulated owl habitat is away from historic stand structures and compositions that favored the 

flammulated owl. In the absence of fire, stand structure and composition would continue to shift to 

Douglas-fir dominance with dense understories and provide poor flammulated habitat. As these stands 

continue on this trend, the increasing fuel loads increase the potential for high intensity fires that would reinitiate stand development. It would take upwards of 200 years to develop flammulated owl habitat in the 

areas burned by high intensity fire (USDA 2000, p. 4.4-Wildlife-8). 

Alternatives 2 and 3 would reduce the trend in loss of quality flammulated owl habitat on the west side of 

the West Fork River. Stands would move toward historic structure and composition and improve

flammulated owl habitat structure in potential and suitable habitat. Similar effects would occur on the east 

side of the West Fork River under Alternative 2 and to a lesser extent, Alternative 3.

Broader Context

The Montana Natural Heritage Program classifies the flammulated owl as a G4 S3B species (MNHP 2007). 

This means that at the global scale, the species is considered to be uncommon but not rare (though it may 

be rare in parts of its range) and usually widespread. It is apparently not vulnerable in most of its range but 

there is possibly cause for long-term concern. At the state scale, the breeding population is considered 
Affected Environment & Environmental Consequences - Wildlife 

3.8-58 Lower West Fork Project Final EIS 

potentially at risk though the species may be abundant in some areas. The breeding population is 

potentially at risk because of limited and potentially declining populations, distribution, or habitat.

The flammulated owl is perhaps the most common raptor of the montane pine forests of the western United 

States and Mexico (McCallum 1994). The Bitterroot NF is near the northeast edge of the known range of 

this species. As of 1998, flammulated owls were considered to have a widespread presence in Missoula 

and Ravalli counties (Wright 1996 and http://nhp.nris.state.mt.us/mbd/).

The number of flammulated owl detections on the Bitterroot NF on unburned transects has remained 

consistent from 2000 to the present. In high and mixed intensity fires that burned through areas known to 

support concentrations of flammulated owls in 2000, about half the number of flammulated owls were 

detected in 2001. Flammulated owl detections on burned transects have continued to decline, and we found 

very few owls in burned areas in 2004 (2004 Monitoring report, PF-WL-016).

We are unsure how these drastic habitat changes will affect the owls that occupied those sites in the long 

term, since no studies have examined the effects of high intensity fire on flammulated owl populations. 

The Region 1 Wildlife Ecologist reviewed population viability and determined that flammulated owl 

habitat is well distributed and abundant in the Northern Region and that short-term viability of the 

flammulated owl in the Northern Region is not of concern (Samson 2005). 

Alternative 1 (No Action)

Determination

Implementation of this alternative would have no impact on flammulated owls or their habitat.

Alternative 2 and Alternative 3

Implementation of Alternative 2 and 3 may impact individual flammulated owls or their habitat, but would 

not likely contribute to a trend towards Federal listing or loss of species or population viability.

Rationale for Determination

Ø There are no measurable impacts with implementation of Alternative 1.

Ø Alternative 2 and 3 incorporated the needs of flammulated owl into the project design and 

mitigations. Stand structures will improve to enhance flammulated owl habitat. Snags 

will be retained consistent with the historic range for that habitat type. Ponderosa pine,

where appropriate, will be favored for retention as flammulated owl habitat. Alternatives

2 and 3 will protect and enhance ponderosa pine reducing the current trend of loss. 

Ø There is a possibility flammulated owls could be disturbed or displaced.

Ø Monitoring shows flammulated owls are well distributed across the forest.

M. Black-backed Woodpecker (Sensitive) 

The analysis for black-backed woodpecker focuses on potential habitat. Potential habitat in the Lower 

West Fork analysis area is inclusively defined as all forested habitat type groups that may experience a fire 

of moderate to high intensity. 

Effects Analysis Method & Reference Conditions

Black-backed woodpeckers prefer recently burned forests, which has led to its listing as a sensitive species. 

Most research on black-backed woodpeckers indicates that they are dependent upon fires, particularly in 

the Northern Rockies (Hutton 1995, Caton 1996, Hitchcock 1996, Murphy and Lehnhausen 1998, Saab and 

Dudley 1998, Hejl and McFadzen 2000). Post-burn area studies in Oregon, Montana, Idaho, and South 

Dakota consistently report wood-boring beetles as an important food source for the black-backed 

woodpecker and occur in abundance 2 to 8 years following a fire. Hutto (1995) stated that the blackbacked woodpecker appears nearly restricted to post-burn areas; and Murphy and Lehnhausen (1998) 

postulated that local populations increase in post-burn areas and decrease in unburned areas. High snag 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-59

densities characterize preferred nesting habitat (Hejl and McFadzen 2000). Post-burn habitat provides ideal 

foraging habitat for black-backed woodpeckers, however it is a short-lived resource. Black-backed 

woodpeckers move into a stand shortly after trees burn, the population usually peaks in two or three years 

(Caton 1996), and the woodpeckers leave the stand five to six years after a fire (Hutto 1995). Fire 

suppression and extensive salvaging of burned trees has probably reduced habitat for black-backed 

woodpeckers across its range. 

Black-backed woodpeckers are found in unburned forests and in areas of insect outbreaks (Marahall 1992), 

but they likely occur at lower densities and viability may not be maintained over time without sufficient 

post-fire habitat. For example, home ranges for black-backed woodpeckers in beetle-killed forests were 

estimated at 1,000 acres, compared to an estimated home range of 56 acres/pair in post-fire habitat (Powell 

2000). Some studies indicate that black-backed woodpeckers forage primarily on woodborers, which may 

explain this difference in suitability between beetle outbreaks and post-fire habitat. Woodborers are much 

less abundant than bark beetles in areas of bark beetle outbreaks (Powell 2000). However, insect outbreak 

studies (without fire) suggest that black-backed woodpeckers are attracted to other insects such as bark 

beetles when they provide an abundant prey base (summarized in Samson 2006). Arnett et al. (1997a and 

1997b) found similar densities of black-backed woodpeckers in mountain-pine beetle activity areas as in 

post-burn areas. These observations suggest black-backed woodpeckers are not restricted to post-burn

areas. Hoyt and Hannon (2002) noted that few studies have considered all habitats in proportion to 

availability or considered the difficulty of comparing bird densities observed in open, post-fire habitats to

bird densities in closed canopy and structurally complex forests.

Several studies have shown that black-backed woodpeckers prefer ponderosa pine, western larch, and 

Douglas fir that have burned at high to moderate intensities (Caton 1996, Hejl et al. 2000, Hutto 1995, 

Powell 2000). Powell (2000) studied black-backed woodpecker habitat relative to prey density in two postfire forests in the Selway-Bitterroot Wilderness of eastern Idaho. Powell (2000, pg 88) stated, “The most 

valuable habitat component may be woodborers rather than a particular tree species, because no single tree 

species is consistently prey rich.” Fires less than 100 acres are valuable for these woodpeckers and one 

black-backed woodpecker nest was found in a 20 acre burn (O’Connor and Hillis 2000). Partially burned 

areas near the perimeter of intensively burned sites provide habitat for diverse assemblages of woodboring 

beetles (Samson 2005, pg. 41).

The Rombo fire burned 25,000 acres in 2007. This is the first sizeable fire within the analysis area since 

the 2000 fire season. The fire burned 11,600 acres (30%) of the analysis area, and currently offers postburn habitat that could support concentrations of black-backed woodpeckers. There is approximately 

13,400 acres of post-burn habitat available outside of the analysis area. Recent mortality due to a variety of 

insect and disease pathogens is likely to affect scattered pockets of trees within the analysis area. Recent 

snags in these areas support populations of various beetles that could provide a food source for blackbacked woodpeckers. 

Affected Environment

There is no shortage of black-backed woodpecker habitat in the Lower West Fork analysis area or on the 

Bitterroot NF. Because black-backed woodpeckers are primarily found in moderate to high intensity

burned areas, potential habitat is readily available from the Rombo fire. 

Approximately all of the Lower West Fork analysis area, 38,400 acres, provides potential black-backed 

woodpecker habitat. Of the potential habitat, approximately 9,050 acres (24%) is suitable habitat defined 

as having been burned in moderate to high intensity fires in the last 6 years. Suitable habitat in the Lower 

West Fork analysis area currently has habitat components necessary to meet the needs of black-backed 

woodpeckers. Based on burned stand characteristics such as the number of trees killed, the potential for 

woodborer populations, and the potential for additional snags weakened by fires and susceptible to 

woodboring insects, the quality of the 9,050 acres of suitable habitat may range from good to excellent.
Affected Environment & Environmental Consequences - Wildlife 

3.8-60 Lower West Fork Project Final EIS 

Potential Impacts to Black-backed 

Woodpecker

Alternatives 1, 2 & 3

No impact

The potential for moderate to high intensity fires is analyzed to determine project effects on potential and 

suitable black-backed woodpecker habitat. 

Alternative 1

Direct & Indirect Effects 

There are no proposed treatments in this alternative, 

therefore no direct, indirect, or cumulative effects would

occur to black-backed woodpeckers or their habitat. If a 

high intensity fire like the Rombo fire occurred, suitable 

habitat for black-backed woodpeckers would increase. 

Alternative 2

The incidental harvest of snags that present an OSHA defined safety hazard would not preclude blackbacked woodpeckers from using the remaining fire or beetle- killed trees as potential foraging and nesting 

areas. 

There are approximately 28 acres of proposed treatments prescribed in currently suitable black-backed 

woodpecker habitat. Low intensity fires are prescribed in most of the project area slated for commercial 

thin or prescribed fire, however, parts or all of three units would be burned in moderate intensity fires. 

Low intensity fires would create pockets of tree mortality that may attract wood boring insects and bark 

beetles; these pockets of mortality would be more prevalent and possibly larger in the areas of moderate 

intensity fires. The treatments in Alternative 2 would reduce the probability of uncharacteristically severe 

fires but they do not prevent the occurrence of natural fire ignitions. Black-backed woodpecker habitat 

would continue to exist though its location would change relative to fire occurrence and insect prey

locations.

Alternative 3

Alternative 3 is very similar to Alternative 2 and proposed treatments would occur on 13 acres of suitable 

black-backed woodpecker habitat. There would be no direct or indirect effects on black-backed 

woodpeckers or their habitat. 

Cumulative Effects & Determinations 

The Lower West Fork analysis area is the black-backed woodpecker cumulative effects analysis area. This 

is the appropriate area to analyze incremental project effects in conjunction with past, present, and 

reasonably foreseeable actions on the black-backed woodpecker. Incremental effects of the alternatives in 

this analysis would not be detectable at a scale larger than the analysis area and it is large enough to 

consider population dispersion to suitable habitat. An assessment of information available at the Forest 

level is also considered to provide additional context.

Geographic Boundaries 

Alternatives

Although past harvest may have reduced black-backed woodpecker habitat in salvage-logged areas into the 

1980s, snags have been retained in harvest units since then. 

Fire suppression may have affected black-backed woodpecker habitat (Canton 1996). Suppression reduced 

the size of fires in the past but also created stand conditions that favored uncharacteristically large fires 

today. Large areas of black-backed woodpecker habitat were created during the fires of 2000 and 

successive years across the Bitterroot NF. Approximately 11,800 acres (4%) of the Bitterroot NF was 

salvage logged following the 2000 fires and about 108 acres of treatment were planned in areas that burned 

in 2003. Approximately 298,000 acres of burned area remains to provide black-backed woodpecker 

habitat. Samson (2005) estimated the percent increase in habitat for each of the National Forests in Region 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-61

All Alternatives ~ Potential 

Impacts to Forest Land 

Birds

No impact to species viability 

for this group

1 between 1990-1993 and 2000 – 2003. He found a dramatic increase of 3,793 percent on the Bitterroot 

NF due to fire and 705 percent increase due to insects.

Because of the large amount of available habitat Forest-wide, the recent occurrence of moderate to high 

intensity fire in 28 percent the analysis area, snag retention in harvest units, and endemic levels of insect 

and disease activity, there would be no cumulative effects on black-backed woodpeckers or their habitat 

from project implementation of any of the alternatives. 

Alternatives 1, 2 & 3

Determination

Implementation of these alternatives would have no impact on black-backed woodpeckers or their habitat.

Rationale for Determination

Treatments would not preclude fires. The result would therefore be a negligible impact on black-backed 

woodpeckers because:

Ø There is a large amount of available habitat Forest-wide

Ø Moderate to high severity fire has occurred recently on approximately 28% of the 

analysis area creating suitable habitat that would be available for up to 6 years

Ø Endemic levels of insects and disease create low-density black-backed woodpecker use 

areas

Ø Snags will be retained 

Ø The probability of high to moderately severe fire is higher in Alternative 1. If this occurs,

there would be more habitat available for black-backed woodpeckers. Management of 

natural ignition fires on the Bitterroot NF creates a continuous supply of black-backed 

woodpecker habitat 

N. Forest Land Birds

Forest land birds include all avian species, except waterfowl and 

game birds. There are more than 100 species of land birds on the 

Bitterroot NF according to our land bird monitoring results. No land 

birds are listed as endangered on the Bitterroot NF, but bald eagles, 

flammulated owls, and peregrine falcons, are listed as sensitive

species. The willow flycatcher and olive-sided flycatcher are listed 

as species at risk in Quigley and Arbelbide (1997). Sauer et al.

(2001), in their analysis of Breeding Bird Survey results, show 

willow flycatchers have declined an average of two percent per year 

over the last 25 years. Olive-sided flycatchers have declined about 5 and 6 percent per year in the same 

time period. Willow flycatchers are shrub associates, and are most abundant in very wet sites. Olive-sided 

flycatchers are most often found around or in recently burned areas, most often nesting in young conifers, 

often lodgepole pine (Baicich and Harrison 1997). In the Northern Rockies, Hutto (1995) found they 

occurred most often in spruce-fir, marsh-wetland, and mixed conifer habitats (Montana Partners in Flight 

2000). 

Affected Environment

Any treatment, including no action, positively affects some species at the expense of others. It would be 

impracticable to treat all the individual species separately. However, individual species’ habitat needs are 

represented by other species discussed in the analysis, e.g. dry site species are represented by flammulated 

owls; old growth associates by flammulated owl, pileated woodpecker, fisher and pine marten; and snag 

dependent species by black-backed and pileated woodpeckers. We assume that maintaining or trending 
Affected Environment & Environmental Consequences - Wildlife 

3.8-62 Lower West Fork Project Final EIS 

habitats toward their historical range of conditions would meet the habitat needs of birds that have evolved 

with and adapted to the vegetation structures and functions characteristic of the Bitterroot NF. 

The Northern Region Forest Land Bird monitoring program monitors land bird populations trends. Since 

the inception of the program in 1994, more than 20 permanently marked, point-count transects have been 

established on the Bitterroot NF. Other land bird monitoring efforts include five Breeding Bird Surveys

that follow FWS protocols established for a nation-wide network, and two Monitoring Avian Productivity 

and Survivorship banding stations that follow the nation-wide protocols established by the Institute for Bird 

Populations. 

Forest personnel also participate in and monitor citizen land bird monitoring efforts, such as the nationwide Christmas Bird Counts and the May Count. The objective of the May Count is to provide an annual,

nation-wide snapshot of bird migration progress on the second Saturday in May. This continuous 

monitoring has not identified any species declines. 

All Alternatives

Direct and Indirect Effects

The proposed activities in the alternatives will benefit some species over others. Those species associated 

with open, large diameter ponderosa pine or mixed ponderosa pine and Douglas-fir forests would benefit 

from the implementation of Alternatives 2 and 3. Those species associated with closed, or dense canopy, 

dry forests would benefit from the implementation of Alternative 1. Effects on snag associated or wetlandassociated species would be neutral under all alternatives as no management is proposed in these habitats. 

Natural ecosystem development changes the composition of land bird populations across the landscape. 

Proposed management activities will not modify habitats beyond the range of natural variation; therefore,

the composition of land bird populations would likely remain within the range of natural variation. 

Cumulative Effects

The Lower West Fork analysis area is the land bird cumulative effects analysis area. This is the appropriate 

area to analyze incremental project effects in conjunction with past, present, and reasonably foreseeable 

actions on land birds. An assessment of information available at the Bitterroot Valley level is also 

considered to provide additional context.

Geographic Boundaries and Time Period 

Constant monitoring of land birds indicates that past actions have not affected land birds overall in the 

Bitterroot Valley. It is highly probable that management actions have caused alterations in habitat that 

favored some species over other species but monitoring indicates that land bird species viability has not 

been affected. Activities that affect the shrub component, a habitat component of many flycatchers, would 

most likely affect land birds in the analysis area. Effects of current actions and proposed alternatives would 

not affect land bird species’ viability. 

Other Actions & Trends

Although livestock grazing has potential to affect land bird species’ viability, management plans and 

existing operating plans appear adequate to maintain and in some cases promote shrub growth in the 

analysis area. The extensive quantity of available post-fire forage in the analysis area and limited number 

of livestock over large areas is expected to disperse livestock use. Minor localized impacts may occur but 

overall, recovery or the quantity of shrubs across the analysis area would not be affected. 

Proposed thinning would enhance the recovery of understory shrub layers by increasing sunlight on the 

forest floor. Riparian habitat conservation areas will preserve the best shrub habitats in the analysis area 

thereby conserving habitat. 
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-63

O. Animal Movement, Migration & Dispersal

Movements by large wide-ranging mammals will be analyzed from a regional perspective, including 

linkages from the Frank Church-River of No Return, Selway-Bitterroot, and Anaconda/Pintler 

Wildernesses to the Allan Mountain Roadless Area, with emphasis on potential barriers to free movement 

into and through the Bitterroot NF. An analysis of animal movement at the local, regional, and grand 

scales was completed in the Trail Creek Supplemental Information Report (USDA Forest Service 1991, 

pages 20-30) and much of that analysis applies to this analysis. We consider daily animal activity patterns 

and their interaction with the habitat at the local scale in the animal movement analysis. Daily activities 

depend on contiguous suitable habitat, or at least suitable food, cover, and water juxtaposed in a small 

enough area for daily use.

Affected Environment

Migration is periodic (seasonal) movement of animals between suitable summer and winter habitat 

(Kendeigh 1961). Some migrations are short such as big game migrations between high elevation summer 

ranges and winter range below high snow accumulation zones. However, neotropical migratory birds 

spend more time during winter in western Mexico than they do in western Montana during breeding season. 

In this analysis, we only have control over lands involved in the shorter migrations between summer and 

winter ranges. We have no control over or direct effect on habitats well beyond National Forest boundaries

and can only maintain suitable seasonal habitats for sustained productivity of long-range migrants.

Dispersal is a one-way outward movement of individuals from suitable, occupied habitat (Kendeigh 1961). 

The movements appear random, almost erratic, and most involve young animals and exchange of genes 

between populations in insular habitats. The habitat needs for dispersing individuals of a population of 

animals is considered in the grand scale analysis. 

Dispersal of individuals between populations of wildlife species is an important component of genetic 

diversity and adaptability of a species to its habitat. Isolated populations are particularly susceptible to loss 

of genetic diversity if no movement among populations occurs. Morrison et al. (1992) postulate that 

providing suitable corridors for successful dispersal of at least one individual per generation can help 

maintain genetic diversity. Dispersing individuals often travel through areas of unsuitable habitat in order 

to reach areas of suitable habitat. 

A corridor is defined as an area through which species can move from one place to another over time in 

response to changes in environment or as a natural part of their life history. The Trail Creek analysis 

(USDA 1991) lists four general characteristics of effective corridors:

Ø "The wider the corridor, the better.” (Noss 1983; Hunter 1990). Acceptable widths will 

vary depending on the habitat structure and quality within the corridor, the nature of 

surrounding habitat, human activities, and the species expected to use the corridor (Noss 

1987). Hunter (1990) noted type of movement is also a factor. 

Ø “The shorter the connection, the better.” (Thomas et al. 1990). Dispersal success 

decreases with increasing distances between habitat blocks.

Ø “Ridges and stream courses provide natural travel ways and their dendritic pattern works 

well to tie various landscape features together (Noss 1983, Harris 1984).

Ø “Corridors comprised of suitable habitat for the species in question work best for 

allowing dispersal (Thomas et al. 1990)." 

The concept of corridors suggests there are specific areas that certain species use to move from one area to 

another. Although there may be preferred travel routes, the historic fire patterns within the Bitterroot NF

and elsewhere in the Northern Rockies, suggests species were able to move freely enough to successfully 

evolve and avoid genetic isolation regardless of the sudden and extensive changes in vegetation from fire.
Affected Environment & Environmental Consequences - Wildlife 

3.8-64 Lower West Fork Project Final EIS 

All Alternatives ~ Potential 

Impacts to Animal 

Movement, Dispersal, 

Migration

No impact

Roads, and the access they provide humans, potentially influence animal movement and vegetation 

patterns. Road impacts on the Bitterroot NF have been partially mitigated with minimal clearing distances, 

low use, and travel restrictions. All of the alternatives would maintain the linkages between refugia like the 

Selway/Bitterroot, Frank Church-River of No Return, and Anaconda/Pintler wildernesses and the Allan 

Mountain Roadless Area because they would maintain vegetation in the treatment units and riparian areas. 

Alternatives 2 and 3 would also close local roads, which may create barriers to smaller, less mobile wildlife 

species. 

Roads are linear features on the landscape that create breaks in forest cover and provide corridors along 

which some plant and animal species can colonize areas they have been excluded from. For example, 

spotted knapweed spreads by vehicles along roads. Roads also increase forest edge and may allow

incursions of species, like the brown-headed cowbird, into forest habitat previously unavailable to them. 

The landscape pattern of vegetation successional stages and topographic features strongly influence daily 

activity patterns of animal populations. All animals need food, cover, and water to survive, and their needs 

must be met within the daily home range. For small mammals, necessities must be met in a few square 

yards, for larger mammals or birds daily movements may occur over several square miles. Existing 

vegetation and fire severity maps reveal a highly variable vegetation pattern with a wide diversity of 

habitats. The analysis also indicates that patch size and connectivity of forested areas have increased since 

the advent of fire suppression thereby favoring those species that need continuous forest environments. 

The same suppression actions have degraded habitat for species that evolved with open forests typical of a 

frequent fire regime. 

The 1987 Northern Rocky Mountain Wolf Recovery Plan delineates the Stateline ridge at the head of the 

West Fork River as a "potential dispersal corridor" between Yellowstone and Central Idaho recovery areas. 

Since the Plan was written, we have found that wolves disperse widely, and do not necessarily follow the 

defined potential corridors. The Final Gray Wolf Recovery Plan changed the recovery zone boundaries and 

did not delineate dispersal corridors (USDI 1994). 

All Alternatives

Direct and Indirect Effects

The intent of proposed activities is to reduce fuels, retain forest cover 

where possible, and regenerate forests where appropriate. None of 

the proposed activities would alter landscapes beyond the range of 

natural variation so none of the activities would substantially 

interrupt current animal movement and dispersal patterns. Reduction 

of forest canopies may alter movement pathways, but not prohibit 

movements between or among forested landscapes. 

Cumulative Effects

The defined effects area for animal movement, dispersal, and migration is the Bitterroot NF. This analysis 

area is appropriate to analyze the incremental project effects on wolves and other wide-ranging animals in 

conjunction with past, present, and reasonably foreseeable actions. 

Geographic Boundaries 

Native wildlife species have evolved in a landscape with a high degree of fragmentation, abundant edge 

and relatively small patch sizes, the result of natural processes and topography. This situation on the 

Bitterroot NF landscape has not changed appreciably by past actions, except for perhaps high volume road 

systems and fire suppression. Highway 93 is the only road that appears to have affected wildlife. Other 

than high volume roads, fire suppression has fragmented the most landscape through development of multiOther Actions & Trends
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-65

storied forests. These multi-storied forests may have reduced preferred flammulated owl habitat. Habitat 

fragmentation has not affected wildlife dispersal or movement between various habitat elements (water, 

forage, winter/summer range, breeding areas) or the viability of wildlife species on the Bitterroot NF, as 

discussed in each of the specific species narratives in this chapter.

All proposed actions would maintain historical vegetation patterns and structures and restore habitat 

conditions typical of Bitterroot NF disturbance regimes.

3.8.6 CONSISTENCY WITH BITTERROOT FOREST PLAN AND OTHER REGULATORY 

DIRECTION

A. Habitat

The Forest Plan objective for old growth habitat is to maintain sufficient old growth habitat to support 

viable populations of old growth dependent species. In several Management Areas or 3rd order drainages,

there is not enough old growth habitat to meet the Forest Plan standard (Table 3.8-2). Since old growth 

habitat requires at least 100 years to develop, the best we can do is maintain the snag and coarse woody 

debris levels within their historic range. None of the alternatives will reduce the amount of old growth 

habitat in the analysis area, because the stands are either untreated or would be treated to retain the old 

growth characteristics, structure, and function that evolved in their habitat types. No snags would be cut 

unless they present an OSHA-defined safety hazard. The proposed Alternatives 2 and 3 treatments would

protect mature stands from stand-replacing fires and promote the development of old growth habitat. 

Old Growth

The Forest Plan requires retaining all snags that do not present a safety hazard. No snags are proposed for 

harvest, which would retain most of the snags in the treatment units. Those snags that fall as a result of the 

treatments would add to the large woody debris component. Snag habitat would meet Forest Plan

standards. 

Snags

B. Management Indicator Species

Thermal Cover

Elk

The Forest Plan Record of Decision requires maintaining thermal cover (trees greater than 40 feet tall and 

greater than 70 percent crown canopy closure) on at least 25 percent of big game winter range. The high 

frequency, low intensity fire regime typical of the low elevation, dry ponderosa pine or mixed ponderosa 

pine and Douglas-fir sites in the analysis area created open forests with grass or shrub understories. 

Proposed harvest and burning treatments in winter range thermal cover would reduce thermal cover but 

protect other resource values at risk. Alternatives 2 and 3 would reduce winter range thermal cover in the 

proposed treatments as discussed in the elk section. Implementation of the action alternatives requires a 

project-specific Forest Plan amendment because both alternatives would reduce thermal cover below the 

standard.

Habitat Effectiveness

None of the alternatives is consistent with EHE standards. The Forest Plan (1987) requires elk habitat 

effectiveness, as measured by open road density, to be maintained in roaded, 3rd order drainages at 50 

percent and in unroaded, 3rd order drainages at 60 percent. There are six 3rd order drainages in the analysis 

areas that currently have open road densities exceeding the standard. Though all but the main road in some 

3rd order drainages would be closed to motorized use under Alternative 3, the standard could not be met 
Affected Environment & Environmental Consequences - Wildlife 

3.8-66 Lower West Fork Project Final EIS 

year-round in all drainages. The proposed site-specific amendment (Chapter 1) would be necessary to 

implement all of the alternatives.

Security

The Forest Plan or other regulatory direction does not require elk security analysis. However, the analysis 

is a good technique to assure the Forest Plan Objective of “maintaining current (1987) level of big game 

hunting opportunities” is met. This objective will be met with all alternatives. 

Overall, proposed activities would not affect elk habitat attributes that would cause elk populations to 

decline. Therefore, potential harvest levels in the analysis area should not decline.

American marten is a Management Indicator Species of mature and old forests. As such, we are required to 

monitor habitat and populations to assure continued pine marten population viability and viability of the 

species it represents. The Bitterroot National Forest Plan Monitoring Report (USDA 2003) summarizes 

pine marten population monitoring efforts. Monitoring indicates pine marten are well distributed across the 

Bitterroot NF. The proposed actions are consistent with regulatory direction to maintain species viability.

American Marten

The pileated woodpecker is a Management Indicator Species for mature and old growth forests. The 

National Forest Management Act requires National Forests maintain viable populations of all native and 

desirable non-native species. None of the proposed actions would affect pileated woodpecker population 

viability, because snags and dead woody material would be retained in the treatment units. The Bitterroot 

Forest Plan Monitoring Report (USDA 2003) summarizes pileated woodpecker population monitoring 

efforts. Monitoring indicates pileated woodpeckers are well distributed across the Bitterroot NF. The 

proposed actions are consistent with regulatory direction to maintain species viability. 

Pileated Woodpecker

C. Threatened and Endangered Species

The Forest Plan objective for threatened and endangered species is to maintain habitat for their recovery. 

The Endangered Species Act requires that any federal agency action does not jeopardize the continued 

existence of any threatened or endangered species or result in the destruction or adverse modification of 

critical habitat. 

Since none of the proposed activities would affect any threatened or endangered species listed on the 

Bitterroot NF, all the alternatives would be consistent with the law and regulation. 

D. Sensitive Species

The Forest Service Manual provides direction for the management of all sensitive wildlife species: 

“Develop and implement management practices to ensure that species do not become threatened or 

endangered because of Forest Service activities.” The Forest Plan standard for sensitive species states, 

“The habitat needs of sensitive species, as listed by the Regional Forester, will be considered in all project 

planning.” This project complies with the Forest Plan and regulatory direction.

E. Other

The land bird monitoring program on the Bitterroot NF responds to regulatory direction to maintain viable 

populations of all native and desired non-native wildlife in habitats distributed throughout their geographic 

range on National Forest. Although population differences are difficult to ascertain because the longest 

standing records are 15 years old and most of the monitoring has been accomplished in the last 10 years, 

the monitoring program has not revealed any species declines.

Forest Land Birds
Affected Environment & Environmental Consequences - Wildlife

Lower West Fork Project Final EIS 3.8-67

Timber harvest and other vegetation management cannot completely avoid unintentional take of birds, no 

matter what conditions are imposed on the activity. The conditions and mitigations proposed in this project 

(such as snag retention, retaining the largest healthiest trees in treatment units, and riparian habitat 

conservation area buffers) would minimize take of migratory birds and retain a diversity of habitats that 

would likely maintain the viability migratory bird populations. 

President Clinton issued an Executive Order on “Responsibilities of Federal Agencies to Protect Migratory 

Birds” on January 10, 2001. In direct response to the Executive Order, the Forest Service and FWS have 

entered into a Memorandum of Understanding to strengthen migratory bird conservation through enhanced 

collaboration between the two agencies, in coordination with state, tribal, and local governments. The

Lower West Fork project supports the conservation of migratory birds and Memorandum of Understanding 

by including the design criteria, mitigations, and site management described above and discussed in the 

effects analysis. 

We have no regulatory direction to address animal movement, migration, and dispersal other than to 

provide habitats that ensures viability of native and desirable non-native wildlife species. 

Animal Movement, Migration, and Dispersal
Affected Environment & Environmental Consequences - Wildlife 

3.8-68 Lower West Fork Project Final EIS 

3.8.7 BIOLOGICAL ASSESSMENT/EVALUATION FOR THREATENED, ENDANGERED,

AND SENSITIVE SPECIES

THREATENED & ENDANGERED SPECIES

Project Name: Lower West Fork 

SUMMARY OF CONCLUSIONS

SPECIES ALT 1 ALT 2 ALT 3

Canada Lynx NE1 NE NE 1

NE: No Effect

s/ David T. Romero

David T. Romero Wildlife Biologist Date: 12/18/09

BIOLOGICAL EVALUATION

SENSITIVE SPECIES

Project Name: Lower West Fork

SUMMARY OF CONCLUSIONS

SPECIES ALT 1 ALT 2 ALT 3

Bald Eagle NI NI NI

Black-backed Woodpecker NI NI NI

Boreal Toad NI MIIH MIIH

Coeur d’Alene Salamander NI NI NI

Fisher NI MIIH MIIH

Flammulated Owl NI MIIH MIIH

Gray Wolf NI MIIH MIIH

Northern Bog Lemming NI NI NI

Northern Leopard Frog NI NI NI

Peregrine Falcon NI NI NI

Western Big-eared Bat NI MIIH MIIH

Wolverine NI MIIH MIIH

NI - No Impact

MIIH -May impact individuals or habitat, but will not likely contribute to a trend 

towards Federal listing or loss of viability to the population or species.

LIFV -Likely to impact individuals or habitat with a consequence that the action may 

contribute to a trend towards Federal listing or cause a loss of viability to the population 

or species.

BI -Beneficial impact

s/David T. Romero

David T. Romero Wildlife Biologist Date: 12/18/09
Affected Environment and Environmental Consequences – Noxious Weeds

Lower West Fork Project Final EIS 3.9-1

3.9 NOXIOUS WEEDS

3.9.1 INTRODUCTION

Invasive species include non-native plants, insects, and pathogens that threaten the health of National 

Forests and Grasslands (USDA Forest Service 2004c). The Forest Service has developed a National 

Strategy and Implementation Plan for Invasive Species to address the threats invasive species pose to 

National Forests and Grasslands (USDA Forest Service 2004c). Short-term actions identified in this 

document include prevention, early detection, and rapid response; control and management; and 

rehabilitation and restoration. This analysis focuses on invasive plants (noxious weeds) present in the 

Lower West Fork analysis area. 

The Lower West Fork project area contains widespread populations of spotted knapweed (Centaurea 

biebersteinii {C. maculosa}) along roads, in previously disturbed areas, and on south and west-facing open 

slopes below 6500 feet. Oxeye daisy (Leucanthemum vulgare) found mostly along roads, is the second 

most common noxious weed in the analysis area. In addition, sulfur cinquefoil (Potentilla recta), St. 

John’s wort (Hypericum perforatum), and hounds-tongue (Cynoglossum officinale) are found less often. 

Cheatgrass (Bromus tectorum), although not listed as a noxious weed, is an invasive non-native species that 

occurs in patches throughout openings in the Lower West Fork area. Cheatgrass was found in burned areas 

after the fires of 2000, particularly under the canopy of ponderosa pine (Pinus ponderosa) where a thick 

needle layer had burned off.

3.9.2 REGULATORY FRAMEWORK

The Forest Plan goal for managing noxious weeds is:

“Control noxious weeds to protect resource values and minimize adverse effects 

on adjacent private land” (USDA 1987, pg. II-3). 

The Forest-wide management standard is the same for all Management Areas and states:

“The primary means of preventing, containing, or controlling noxious weeds will 

be through vegetative management practices and by the use of biological agents 

such as insects, rusts, molds and other parasites on host plants. However, 

herbicides may be utilized to provide short-term protection on specific sites, after 

appropriate environmental analysis.”

The 2001 supplement to the Forest Service Manual (FSM 2080) (PF-NOX-003) outlines an Integrated 

Weed Management approach for the control of noxious weeds on National Forest System lands in Region 

One. Included in the supplement are requirements and recommendations for noxious weed management 

when conducting ground–disturbing activities. In order to prevent weed establishment one of the required 

objectives is to:

“Revegetate all disturbed soil, except the travel way on surfaced roads, in a 

manner that optimizes plant establishment for that specific site, unless ongoing 

disturbance at the site would prevent weed establishment. Use native material 

where appropriate and available. Use a seed mix that includes fast, early season 

species to provide quick, dense revegetation. To avoid weed contaminated seed, 

each lot must be tested by a certified seed laboratory against all the Montana 

State noxious weed lists and documentation of the seed inspection test provided.” 

Certified weed free or weed seed free hay, mulch, seed and pellets are required to be used on National 

Forest (PF-NOX-003). The list of recommended seed mixes for use on the Bitterroot National Forest is in 

the project file (PF-NOX-001).
Affected Environment and Environmental Consequences – Noxious Weeds

3.9-2 Lower West Fork Project Final EIS

3.9.3 AREA OF ANALYSIS 

The noxious weed analysis area is the same as the watershed analysis area in the lower West Fork of the 

Bitterroot River. The analysis area is bounded by the Darby Ranger District on the north and on the south 

by Wheeler and Castle Creeks, on the west and east sides of the West Fork River, respectively. The 

analysis area extends west to the Selway-Bitterroot Wilderness boundary and east to the Sula Ranger 

District. 

3.9.4 EFFECTS ANALYSIS METHODS

The effects analysis considers the following to determine the potential extent of weed invasion or 

expansion:

Ø proposed harvest method

Ø fuels treatment 

Ø presence of existing noxious weed populations

Ø proximity to roads or trails

Ø elevation

Ø aspect 

Information from “An Evaluation of Noxious Weeds on the Lolo, Bitterroot, and Flathead National Forest” 

(Losensky 1987) was also incorporated into the assessment. Generally, removal of the tree canopy and soil 

disturbance increases the risk of invasion (Losensky 1987). Spotted knapweed is particularly responsive to 

this type of disturbance. 

Information used in this effects analysis came from extensive plant surveys conducted in the Nez Perce 

Fork Vegetation Management Environmental Assessment (1996-98), the Frazier Interface Environmental 

Assessment (2002), the School Point Ecoburn (2005), and the Lower West Fork project area from 2005-

2007. 

The Threatened, Endangered, and Sensitive Plants effects analysis (section 3.11 of this chapter) also 

discusses noxious weeds, since the spread of weeds into sensitive plant habitat is one of the main threats to 

species’ viability. This section should be reviewed in order to fully understand the effect of noxious weeds 

on plant diversity and habitat quality. 

3.9.5 EXISTING CONDITION 

One unit in the analysis area, unit 83, does not have noxious weed infestations. Spotted knapweed grows 

throughout the analysis area on south and west facing slopes at elevations below 6500 feet. It grows on dry 

sites, particularly along roads, in old cutting units, and within large openings. Higher elevation grasslands 

in the upper Piquett Creek drainage have escaped heavy infestations of invasive plants but spotted 

knapweed occurs along ridgetop trails in the Shook Mountain area. 

More recently, occurrences of sulfur cinquefoil threatens additional displacement of native plants. Sulfur 

cinquefoil may be more of a threat to the native plant community than spotted knapweed. Cattle and 

wildlife will often graze spotted knapweed plants but the high tannin content of sulfur cinquefoil makes it 

unpalatable to most livestock and wildlife (Rice et al. 1994). Grasslands presently under ecological stress 

from the invasion of spotted knapweed could undergo even greater stress if subjected to the cumulative 

effects of a second non-native component. The result is likely to be habitats with little or no similarity to 

their potential natural communities. Sulfur cinquefoil occurs at the mouth of Pierce Creek along a Forest 

Service road.

St. John’s wort and oxeye daisy have rhizomatous growth patterns, which makes them extremely difficult 

to eradicate. St. John’s wort occurs along roads in the Wheeler and East Piquett drainages. Oxeye daisy 

tends to grow in moister sites than the other noxious weeds, and occurs along roads in the Baker, Wheeler, 

Piquett, and East Piquett drainages. Most oxeye daisy locations on the Bitterroot National Forest occur 
Affected Environment and Environmental Consequences – Noxious Weeds

Lower West Fork Project Final EIS 3.9-3

along roads, but it can take over openings adjacent to roads. Cheatgrass is scattered throughout the project 

area, in openings and previously burned areas. Hounds-tongue occurs along roads in the Christisen/Lloyd 

Creek area. 

Some roads in the Lower West Fork analysis area have been treated with herbicides, as analyzed in the 

1998 Noxious Weed Environmental Assessment (PF-NOX-002). These include NFSRs 5629A, 5634, 

13826, 62419, 74007, 74348, 74350, 74351, 74354, 74357, 74358, and the Boulder Creek Trailhead. In 

addition, the Selway-Bitterroot Wilderness Invasive Plants Management Project Draft Environmental 

Impact Statement (DEIS) (USDA 2008) proposes to treat areas on the west side of the Lower West Fork 

project area leading into the Selway-Bitterroot Wilderness. This herbicide use would prevent transporting 

noxious weeds into the Wilderness. The areas treated and proposed for treatment does not include all the 

infested areas in the Lower West Fork analysis area. 

A. Species Information

Spotted knapweed currently infests about 264,000 acres of the Bitterroot National Forest (USDA Forest 

Service 2003a). It generally occurs at elevations below 6,500 feet, except on south aspects. There is a 

strong correlation between canopy closure and spotted knapweed infestation; the more sunlight reaching 

the forest floor, the higher probability of infestation. Spotted knapweed infestation is also correlated with 

aspect, soil type, and the degree of soil disturbance. It is most commonly found in pastures on dry, sterile, 

gravelly, or sandy soils, and will quickly invade disturbed sites such as road and railroad rights-of-ways, 

waste places, abandoned fields, timber harvest units and overgrazed rangeland. Ponderosa pine and 

Douglas-fir/bunchgrass habitat types, dry shrub communities, and scree slopes are the most susceptible to 

knapweed invasion (Losensky 1987). Spotted knapweed is usually not found in shaded areas, or on 

cultivated land or irrigated pasture. 

Spotted Knapweed (Centaurea biebersteinii {C. maculosa})

Spotted knapweed prefers the warm, dry ponderosa pine and Douglas-fir habitat types which historically 

burned at an interval of 5 to 25 years (USDA Forest Service 1995a). Fire suppression has increased this 

interval to about 50 years, resulting in higher fuel loads and the potential for a severe fire event in these 

areas. In western Montana, it appears that the more vegetation consumed in a fire on sites previously 

infested with spotted knapweed, the higher the probability of spotted knapweed spreading into newly 

opened areas in the immediate vicinity. Observations two years after the wildfires of 2000 on the Bitterroot 

National Forest indicate that areas where spotted knapweed was previously established have notably 

healthier looking plants with new seedlings colonizing the site and spreading to previously weed-free areas 

(Sutherland 2003). Another post-fire study revealed that over time, spotted knapweed populations 

increased more on Douglas-fir habitats that burned at higher severities than at lower burn severities 

(Ferguson et al. 2007).

Current treatments for spotted knapweed include mechanical (hand pulling and mowing), biological, and 

chemical. Hand pulling has proven to be up to 35% effective, costs up to $8,498 per acre and can only be 

accomplished for small areas (USDA Forest Service 2003a). Mowing at recreation sites prevents the plants 

from setting seed but does not reduce the number of plants. Several biological agents specific to spotted 

knapweed have been released throughout the Forest (Table 3.9-1). 

Biological controls are a long-term solution, and decreases in spotted knapweed infestations are not 

expected until these insect populations increase. Biological control agents should decrease spotted 

knapweed seed production by up to 80% once they become well established. In the meantime, chemical 

control methods (especially Tordon) appear to be the most successful for treating small spotted knapweed 

infestations or to aid in containment of existing populations. Since almost 20% of the Bitterroot National 

Forest is infested with spotted knapweed a containment strategy is being used to keep it from spreading into 

currently un-infested areas (USDA Forest Service 2003a). 
Affected Environment and Environmental Consequences – Noxious Weeds

3.9-4 Lower West Fork Project Final EIS

St. John’s wort is known to infest about 750 acres of the Bitterroot National Forest (USDA Forest Service 

2003a). Populations are scattered throughout the Forest and appear to have no affinity to a particular 

habitat type. Road shoulders provide the most likely location for St. John’s wort; otherwise, it has been 

associated with logging, grazing, or fire disturbance. In grass communities, it appears to out-compete 

spotted knapweed, but is not as competitive in forested areas (Losensky 1987). Each plant may produce 

anywhere from 15,000 to 30,000 seeds (Zouhar 2004). 

St. John’s Wort, Goatweed (Hypericum perforatum) 

A containment strategy including mechanical and chemical treatment methods has been recommended on 

the Bitterroot National Forest. Biological control agents are available but their use on the Forest hasn’t yet 

been successful (USDA Forest Service 2003a). 

Table 3.9- 1: Biological Agents Used on the Bitterroot National Forest

Over 2,500 acres of the Bitterroot National Forest are infested with sulfur cinquefoil (USDA Forest Service 

2003a). Sulfur cinquefoil is adapted to a wide range of environmental conditions. It has been found 

growing in open forests, grasslands and disturbed areas, often in association with spotted knapweed. Sulfur 

cinquefoil is a prolific seed-producer (about 1600 seeds per plant) and has been known to displace spotted 

knapweed in mixed stands. It is unknown whether this is a successional mechanism or a result of herbicide 

and/or biological controls targeting spotted knapweed (Zouhar 2003b). 

Sulfur Cinquefoil (Potentilla recta)

A containment strategy using chemicals is recommended for sulfur cinquefoil. No other method of control 

appears to be as effective for this weed species. Biological control agents are currently being studied 

(USDA Forest Service 2003a). 

Hounds-tongue infests over 500 acres of the Bitterroot National Forest. Hounds-tongue is typically found 

along roadsides, trails, and areas disturbed by grazing and timber harvest. Infestations are fairly localized 

and do not appear to be expanding (USDA Forest Service 2003a). Each plant may produce from 300 – 675 

seeds. Long distance dispersal is a threat because a barb-covered husk that sticks to fur and clothing 

encloses hounds-tongue seeds (Zouhar 2002b).

Hounds-tongue (Cynoglossum officinale)

Containment strategies for small hounds-tongue infestations recommend using chemicals, or pulling and 

removing plants and seeds. 

Oxeye daisy infests about 300 acres of the Bitterroot National Forest (USDA Forest Service 2003a), with 

most infestations occurring along roadsides and trails. Moist sites such as mountain meadows and riparian 

Oxeye Daisy (Leucanthemum vulgare)

Species Type of insect Mode of Action (general)

Agapeta zoegana moth Root miner

Bangastemus fausti weevil Seed head feeder

Chaetorellia acrolophi fly Seed head feeder

Cyphocleonus achates weevil Root miner

Larinus minutus weevil Seed head feeder

Larinus obtusus weevil Seed head feeder

Metzneria paucipunctella moth Seed head feeder

Pelochrista medullana moth Root miner

Sphenoptera jugoslavica beetle Defoliator, root miner

Terellia virens fly Seed head feeder

Urophora affinis fly Seed head feeder

Urophora quadrifasciata fly Seed head feeder
Affected Environment and Environmental Consequences – Noxious Weeds

Lower West Fork Project Final EIS 3.9-5

areas are most susceptible to invasion by this species. Each plant can produce up to 26,000 seeds, but its 

rhizomatous nature (ability to root from stems) allows it to form dense stands, choking out native 

vegetation (Krueger and Sheley 2002). Oxeye daisy appears to be expanding throughout the Forest (USDA 

Forest Service 2003a).

A suppression/containment strategy is recommended for oxeye daisy using chemicals and some handpulling (USDA Forest Service 2003a). 

Although not listed in Montana as a noxious weed, cheatgrass is of concern on the National Forest because 

of its capacity to alter fire regimes. Cheatgrass is commonly associated with disturbed areas, such as 

recently burned range and wildlands, roadsides, and eroded areas. Cheatgrass seedlings usually germinate 

with fall moisture and the root system develops throughout the winter. The well-developed root system 

exploits the spring moisture and nutrients before native species are able to germinate. Cheatgrass typically 

dries out and disperses seed by mid-June. The fine structure and ability of the plant to dry completely, and 

accumulate litter make it extremely flammable. In the Snake River Plains of Idaho, cheatgrass has changed 

the fire cycle from 30-100 years to 3-5 years. These fires are more intense and less patchy than historical 

fire regimes and change native plant diversity (Zouhar 2003a). 

Cheatgrass (Bromus tectorum)

Currently the Sula Ranger District is using fire and chemical treatments, followed by seeding with native 

species to contain cheatgrass spread. 

3.9.6 ENVIRONMENTAL CONSEQUENCES

A. Effects Common to All Alternatives

All action alternatives that involve timber harvest and under burning on lower elevation south or west 

facing slopes have the potential for spreading noxious weeds - particularly spotted knapweed. Weeds are

spread by harvest equipment and exposure of mineral soil, the creation of forest canopy openings, and the 

release of seed stored in the soil. To some extent, all the alternatives would open the forest canopy and 

expose mineral soil. Under the No Action alternative, Alternative 1, canopy openings and mineral soil 

exposure would result from natural processes. Under the action alternatives, Alternatives 2 and 3, they 

would result from the management activities. The effects these activities have on weed spread also affect 

competition between threatened, endangered, and sensitive plants, and noxious weeds. These effects are 

discussed in section 3.10 of this Chapter. 

The commercial thin units have the highest potential of increasing noxious weed infestations because the 

treatments would expose mineral soil and open the canopy. Equipment needed to yard the trees from the 

units would facilitate seed transport to new areas. Tractor harvest typically disturbs up to 5% of the soil in

a unit and skyline cable harvest disturbs between 2 to 5% of the soil. In addition to the skid trails and 

skyline corridors, temporary roads and tracked line machine trails (TLM) would expose mineral soil and 

create areas susceptible to weed infestation. Soil disturbance associated with these activities creates a 

noxious weed seedbed, and the equipment could distribute the seed from infested areas to the newly created 

seedbed. Harvest equipment and other vehicles associated with the timber sale could also spread noxious 

weeds beyond the unit and the analysis area. 

Post harvest burning would also contribute to weed spread. Spotted knapweed, hounds-tongue, sulfur 

cinquefoil, St. John’s wort, and cheatgrass are all adapted to fire and would spread after burning. Houndstongue would be vulnerable to very hot burns but would spread after a moderate severity burn (Zouhar 

2002b). On the other hand, cheatgrass appears to increase more on severely burned sites than on burns of 

moderate severity (Zouhar 2003a), so low severity fires would not favor cheatgrass spread. Spotted 

knapweed would increase if it is already on site prior to burning and may spread to adjacent sites with

exposed mineral soil (Sutherland 2003). St. John’s wort spreads by rhizomes and seed following fire. Its 

seed appears to remain viable for several years and disturbances such as timber harvest and burning 
Affected Environment and Environmental Consequences – Noxious Weeds

3.9-6 Lower West Fork Project Final EIS

activate seed germination (Zouhar 2004). The degree of response depends on season of burning and other 

vegetation growing on the burn site (Zouhar 2004). The effects of fire on oxeye daisy are unknown but we 

expect its response to fire would be similar to St. John’s wort since both species are rhizomatous. It would 

likely respond well to moderate and high severity fires (Brown and Smith 2000). 

All commercial harvest units would be underburned following the harvest. Exposed soil, in addition to the 

boost in growth weeds receive following the fire, would make the commercial thin units more susceptible 

to. Tractor units would have a slightly higher infestation potential than cable skyline units. Noncommercial thin units would have a lower potential for increasing noxious weed infestations since heavy 

equipment will not be used, mineral soil will not be exposed, and the units will not be underburned. 

B. Direct and Indirect Effect

The No Action alternative proposes no ground disturbing or prescribed fire activities. However, the plant 

communities that occur in the lower elevations of the Lower West Fork analysis area are adapted to 

frequent, low intensity fires (Arno 1976). Most of the species found in these plant communities have below 

ground woody root systems that should easily survive the flashy types of fires that historically burned 

through open ponderosa pine stands. With continued fire suppression, fuel loadings will increase and a 

wildfire occurring in the area could be more severe, increasing the possibility of soil heating and damage to 

below ground plant tissue. Severe fires may also expose more mineral soil and increase colonization by 

spotted knapweed and other noxious weeds. Native plant species would be less able to recover and 

compete with encroaching weed species if they are damaged by intense heat. After the wildfires 2000, 

research plots were established throughout the Forest to determine how fire affects weed distribution. 

Initial results indicate that vigor increased in spotted knapweed plants present before the fire, and new 

seedlings grew on the exposed soil the second year after the fires - on sites where spotted knapweed existed 

and on adjacent, previously weed-free areas (Sutherland 2003). 

Alternative 1, No Action

In the absence of wildfire in the Lower West Fork area wildlife, livestock, humans, off-road vehicles, or 

wind can spread noxious weeds by transporting weed seed into natural stand openings (Zouhar 2001). 

However, it is more likely that weeds will spread into canopy openings created in areas that are adjacent to 

weed-infested sites. Spotted knapweed has an affinity for open areas on dry aspects and can still invade 

these openings without soil disturbance as long as a seed source is available nearby (Zouhar 2001). 

Alternative 2 (Proposed Action) proposes both commercial and non-commercial vegetation management 

treatments on the east and west side of the West Fork River. Herbicide applications are proposed for all 

roads accessing harvest and burn units where weeds are present; roads proposed for storage or 

decommissioning; terraces; and landings and temporary roads prior to rehabilitation. Other disturbed areas 

would be sprayed if monitoring indicates invasive species are encroaching post-treatment. This may 

include skid trails, TLM trails, burn piles, and openings created by harvest. 

Alternative 2, Proposed Action

Effects of Harvest Activities and Prescribed Fire

Vegetation treatments have the potential to spread noxious weeds, regardless of treatment. Application of 

required prevention and control measures (FSM 2081.2) would limit or prevent the spread of weeds (see 

Chapter 2, Mitigation). Equipment used to yard timber from the units would be cleaned of weed seeds 

prior to entering the sale area. We will rehabilitate skyline harvest corridors or skid trails created by 

ground-based harvest equipment by pulling the displaced soil and vegetation back into the corridor or on 

the skid trail immediately after use. The disturbed areas would be fertilized and seeded as soon as feasible 

for best seed germination (see Mitigation Measures in Chapter 2). If possible, temporary roads and TLM 

trails would be treated with herbicides prior to obliterating, fertilizing, and seeding. Old skid trails would 

be used when possible to limit the area of disturbance and confine weed infestations to previously disturbed 

areas. These practices would occur in all commercial thin units regardless of weed infestation level since 
Affected Environment and Environmental Consequences – Noxious Weeds

Lower West Fork Project Final EIS 3.9-7

Table 3.9-2: Noxious Weed and Cheatgrass Locations in Alternatives 2 and 3(Units not listed did not 

contain plants or suitable habitat)

1 Yarding method: T = Tractor; SL = skyline cable; Te = Terrace; PF = Prescribed Fire; NCT = Non-commercial thin. 2 X = present; RS = Roadside

weeds were found in every unit proposed for commercial thinning (Table 3.9-2). These practices would 

limit the introduction of new noxious weeds from outside the project area and limit the distribution of 

weeds to new areas within the project area. We will apply herbicide spot treatments if post-treatment 

monitoring indicates noxious weeds are moving into previously uninfested areas. Unit Alternative Spotted knapweed Oxeye daisy Sulfur cinquefoil St. John’s wort Hounds- tongue Cheatgrass Yarding method1 Unit Alternative Spotted knapweed Oxeye daisy

St. John’s wortHoundstongueCheatgrassYarding method1

1 2,3 X1 T,SL 61a 2,3 X X PF

2 2,3 X X X X T,SL 62 2,3 X T,SL

3 2,3 X X T,SL 63 2,3 X PF

4 2,3 X T 63b 2,3 X X PF

5 2,3 X T,SL 64 2,3 X X PF

6 2,3 X T 65 2,3 X X PF

7 2,3 X SL 66 2 X X PF

8 2,3 X T,SL 68 2,3 X X T

9 2,3 X T,SL 69 2,3 X X PF

10 2,3 X RS2 RS T,SL 70 2,3 X PF

11 2,3 X X T,SL 71 2 X X PF

12 2,3 X X T,SL 72 2 X X PF

13 2,3 X X X T,SL 73 2 X PF

14 2,3 X X Te,T,SL 74 2 X X PF

15 2 X T,SL 75 2,3 X TeNCT

16 2 X T,SL 80 2,3 X NCT

18 2 X X SL 81 2,3 X Te,SL

19 2 X X T,SL 82 2,3 X X NCT

20 2 X X T,SL 83 2,3 NCT

21 2,3 X X X Te,SL 84 2,3 X NCT

22 2,3 X X SL 85 2 X X X NCT

23 2,3 X X SL 86 2,3 X X X Te,SL

24 2,3 X X T 87 2 X X X NCT

25 2,3 RS Te,T,SL 88 2,3 X Te,T,SL

26 2 RS SL 89 2,3 X X X Te,SL

27 2,3 RS Te 90 2,3 X Te,T,SL

28 2 X X X SL 91 2 X NCT

29 2 X X T,SL 92 2 X X NCT

32 2,3 X PF 93 2 X X NCT

33 2,3 X PF 94 2 X NCT

34 2,3 X T 95 2 X NCT

35 2,3 X Te,T,SL 96 2 X NCT

40 2 X X SL 97 2 X X NCT

41 2 X T 98 2 X NCT

42 2 RS X T,SL 99 2,3 X X X Te,SL

60 2 X T,SL 100 2,3 X X PF

60a 2,3 X PF 101 2,3 X X NCT

61 2,3 X X T,SL 102 2 NCT
Affected Environment and Environmental Consequences – Noxious Weeds

3.9-8 Lower West Fork Project Final EIS

The units treated with prescribed fire only would burn at low severity, except unit 32, 33, and the higher 

elevations of 61a, which would burn at moderate severity. Spotted knapweed occurs in all these units 

except 60a, and cheatgrass occurs in all units except 32, 33, 61a, 63, 70, and 73. Hound-tongue occurs only 

in unit 61a (Table 3.9-2). Spotted knapweed and hounds-tongue plants may become more robust after the 

burns but we would not expect an increase in the infestations since the low fire severity would not expose 

mineral soil. Cheatgrass infestations would likely remain at current levels since none of the prescribed fires 

would be high intensity. Hand piles in the project area would be small enough in size (10 feet in diameter 

by 6 feet high) to reduce the risk of burning to mineral soil and/or destroying existing native vegetation (see 

Mitigation Measures in Chapter 2). 

Tractor harvest over bare ground may adversely affect some sensitive plant habitat due to the high 

likelihood of spreading noxious weeds. Summer tractor harvest disturbs soil (up to 15%) and increases the 

risk of transporting weed seed into the unit. There is a high potential of spreading weeds further when 

using equipment over weed-infested ground. Units 1-6, 8-16, 19, 20, 24-26, 29, 34, 35, 41-42, 60, 61, 62, 

68, 88, and 90 will be tractor harvested, which will expose mineral soil. All of these units except 60 have 

known populations of spotted knapweed (Table 3.9-2). Unit 60 has the open habitat that spotted knapweed 

prefers. In addition, unit 2 contains sulfur cinquefoil and oxeye daisy; unit 10 has St. John’s wort and 

oxeye daisy along roads in the unit; and units 11, 12, and 13 contain oxeye daisy. Cheatgrass, an invasive 

annual grass species, was also found in units 2, 3, 13, 14, 19, 20, 24, 29, 60, 61, and 68.

Mitigation measures should be strictly followed to prevent the introduction or spread of weed seed into the 

harvest unit in all of the above units containing invasive plant species. After completion of timber harvest, 

vegetation and soil removed in skid trails should be pulled back over the trails where feasible to replenish 

the native seed source. Skid trails should be seeded as soon as possible after use if disturbance has created 

large areas of bare soil. Native shrubs can also be planted if available to restore root structure to the soil 

and speed up vegetative recovery improving the sites’ capability to compete with weeds. 

The risk of weed spread intensifies in these tractor units with the reintroduction of fire. The combined soil 

disturbance from summer tractor harvest and fire may promote weed infestation, particularly if burning is 

done in areas where ground disturbance has occurred or conditions are very dry (i.e. fall burning). Jackpot 

and broadcast burning accomplished under cool spring conditions may decrease the risk of weed spread 

since native vegetation would have a chance to recover. All of the tractor units will be burned after harvest, 

though some units will not be burned for at least five years post-harvest. This may give native or seeded 

vegetation in skid trails a chance to recover prior to burning. 

Skyline cable harvest is proposed for units 1-3, 5, 7-23, 25, 26, 28, 29, 35, 40, 41, 42, 60, 61, 62, 68, 81, 86, 

88-90 and 99 (Table 3.9-2). Skyline cable harvest can disturb from 2 to 5% of the soil. All of these units 

except 60 have known populations of spotted knapweed. In addition to the weeds noted above in the 

tractor units, units 21, 23, 28, 86, 89, and 99 contain oxeye daisy, and cheatgrass is found in unit.18, 21, 22, 

28, 40, 86, 89, and 99.

As in units logged with tractors, noxious weed mitigation measures should be strictly followed in cable 

harvest units to prevent the introduction or spread of weed seed in the unit. If logs are fully suspended 

there should be very minimal soil disturbance. Logs that are dragged up by one end can tear up the soil and 

vegetation in the skyline corridor creating sites for weed colonization. If no weeds are in the area and 

vegetation is replaced in cable corridors after harvest, the risk of weed encroachment would be minimal. 

The risk of weed spread intensifies in skyline units with the reintroduction of fire, although ground 

disturbance from harvest activities will be less than for tractor harvest. Burning during the cooler, moister 

spring months may result in less ground disturbance. 

Units 32, 33 and the upper portion of unit 61A will be burned in the fall to achieve a mixed severity burn 

with the potential for more ground disturbance. Since these units do contain some spotted knapweed there 

is greater potential for weed spread with higher severity burning (see “Effects Common to All Action 
Affected Environment and Environmental Consequences – Noxious Weeds

Lower West Fork Project Final EIS 3.9-9

Alternatives”). Unit 61A also has some houndstongue along the roads. Most other units will be burned 

under spring conditions when fire severity and ground disturbance would be lower because the soil is 

moister. Units 60A, 63B, 64, 65, 66, 69, 71, 72, and 100 also contain cheatgrass, which responds well to 

fire. Cheatgrass establishes from seed that is either stored in the soil seedbank or comes into newly firedisturbed sites from adjacent areas (Zouhar 2003). There is potential with spring burning to actually kill 

cheatgrass seedlings, but a fire that would be hot enough to damage seedlings may also damage cool season 

native perennial bunchgrasses (Zouhar 2003). A hotter fall burn may reduce the pine litter layer under 

ponderosa pine trees; and cause a flush of cheatgrass germination (Gundale et al. 2007). There is not 

enough information currently available on the effect of fire on houndstongue. In northeastern Oregon,

houndstongue did not establish on a severely burned site, but did establish on a moderately burned site 

(Zouhar 2002b). 

Spot herbicide treatments would be applied to noxious weeds if post-treatment monitoring indicates they 

are dispersing into previously uninfested areas. 

Temporary roads or TLM trails would not adversely affect sensitive plants or their habitat. If sensitive 

plants are discovered during project implementation, temporary roads or TLM trails would be relocated. 

Many of these proposed roads and TLM trails are currently infested with spotted knapweed and patches of 

cheatgrass. Temporary roads will be ripped, obliterated, and revegetated, and TLM trails will be 

revegetated after use to help prevent further weed spread (as part of Standard Timber Sale Contract). 

Temporary Roads and TLM Trails

Watershed Restoration

Watershed improvement projects would decommission and store 10 and 19 miles of road, respectively, 

which would remove 22 culverts. In the long term, these activities would reduce the spread of invasive 

plants by closing off corridors on which they spread. Road corridors would first be sprayed with herbicides 

to kill noxious weeds prior to closing the road. This would also decrease competition for grass 

establishment after seeding. Road entrances and culvert removal areas would then be recontoured to 

restore natural drainage. Finally, these areas would be fertilized and revegetated by seeding with grass and 

planting shrubs. Fertilization and revegetation would enhance native plant competition against potential 

noxious weed encroachment. 

In addition, about 250 acres of soil restoration would occur on terraced plantations after thinning. Terraces 

would be “ripped” or “subsoiled” to reduce compaction and enhance native plant root penetration. A slowrelease organic fertilizer would be applied to restore soil nutrients and organic matter. “Ripping” has the 

potential to disturb vegetation and create sites for noxious weed germination. Terraces that have a high 

concentration of invasive plants would also be seeded and planted with native grasses, forbs, and shrubs. 

Herbicides would be applied to terraces prior to decompaction to improve native plant establishment by 

reducing the productivity of noxious weeds. 

Herbicide Treatments

The Lower West Fork Project tiers to the Selway-Bitterroot Wilderness Invasive Plants Management

Project DEIS (USDA 2008d) for details on potential herbicides, potential target species, and effects of 

different herbicides on native and sensitive plant species (tier to section “3.1 Vegetation”). Vegetation 

Response Units (VRUs) as described in the Lower West Fork Project would be used to describe cover types 

rather than the VRUs used in the Selway-Bitterroot Wilderness Invasive Plants Management Project DEIS. 

Herbicide treatments would be restricted to Lower West Fork VRUs 1-3 (mostly grasslands, ponderosa 

pine, and dry Douglas-fir cover types). About 1,400 acres of the Lower West Fork project area would 

potentially require herbicide treatment. This estimate includes the area of roads, trails, landings, terraces, 

and treatment areas. However, no more than 300 acres would be treated in any one year for up to ten years. 

Herbicide would be applied within units if post-harvest monitoring indicates weeds have encroached onto 

previously weed-free areas. No herbicides would be applied directly on known sensitive plants, though 

herbicides may be used in the vicinity of sensitive plants to reduce noxious weed encroachment. Target 
Affected Environment and Environmental Consequences – Noxious Weeds

3.9-10 Lower West Fork Project Final EIS

species would most likely be one of the invasive species known to be currently present in the Lower West 

Fork project area: spotted knapweed, oxeye daisy, sulfur cinquefoil, St. John’s wort, houndstongue, and 

cheatgrass. Other invasives that could be found within the project area include Canada thistle (Cirsium 

arvense), common tansy (Tanacetum vulgare), and tall buttercup (Ranunculus acris). Potential new 

invaders that have been found on the West Fork Ranger District but not within the project area include rush 

skeletonweed (Chondrilla juncea) and blueweed (Echium vulgare), as well as other invasives from Idaho or 

from the northern part of the Bitterroot Forest like yellow starthistle (Centaurea solstitialis), leafy spurge 

(Euphorbia esula) and dalmation toadflax (Linaria dalmatica). If any of these or other new invaders is

detected in the project area, they would be treated immediately with herbicides to prevent establishment. 

Roadside applications would use a truck-mounted, computer-monitored boom sprayer or a handline on a 

reel to treat infestations within the rights-of- ways of designated roads. This application method is less 

selective than hand spot-spraying but is still capable of providing a high degree of precision and 

minimizing non-target plant mortality. Backpack or horsepack sprayers would be used for spot treatments 

in units or areas with difficult vehicle access. 

Herbicide effectiveness monitoring is a continuous process on the Bitterroot Forest. The 2007 Bitterroot 

National Forest Plan Monitoring and Evaluation Report discusses invasive plant species being treated with 

herbicides and the effectiveness of those treatments. Spot spraying of spotted knapweed along hiker trails 

has resulted in up to a 90% reduction in canopy cover with little impact on surrounding native vegetation 

(USDA 2007a). Records are maintained on the Bitterroot National Forest from applicator contract 

inspections and are available in the project file for the Selway-Bitterroot Wilderness Invasive Plant 

Management DEIS. 

Effectiveness of Herbicide Treatments

Peter Rice and Mick Harrington studied prescribed fire and herbicide effects on plant communities in the 

Sawmill Research Natural Area (Rice and Harrington 2003). Herbicide treatments were initiated in 1996 

and 1998and produced the following results:

Ø Spotted knapweed canopy cover was reduced from 25% to 3%, and remained at 4% through 

2002

Ø Bunchgrass abundance increased from 161 lbs/acre to 566 lbs/acre

Ø Forb cover decreased initially but recovered to almost pre-spray levels by the third year (Rice 

and Harrington 2003). 

Under Alternative 3, an additional 17.2 and 0.6 miles of road would be decommissioned and stored, 

respectively, which would remove 11 more culverts than in Alternative 2. There would also be less 

thinning, both commercial and noncommercial, than in Alternative 2. Soil restoration work on terrace units 

will be the same as in Alternative 2. No herbicide treatments are proposed other then what has already 

been analyzed in previous NEPA documents. 

Alternative 3

Effects of Harvest Activities and Prescribed Fire

Under Alternative 3, skyline harvest would occur on about 195 less acres and tractor harvest about 540 less 

acres than Alternative 2. Therefore, there would be a lower probability of spreading noxious weeds 

through ground disturbance. These untreated areas would be more susceptible to wildfire in the future. 

Most of these untreated areas are outside the wildland urban interface (WUI). Though we cannot predict 

the risk of a wildfire coming through this area with certainty, a wildfire burning through heavy fuel loads 

would burn at high severity. This occurrence would benefit noxious weeds and cheatgrass in particular, 

and enable them to encroach in adjacent, previously weed free areas.

Effects of the treated units would be the same as under Alternative 2 and the same mitigation measures 

would be applied. 
Affected Environment and Environmental Consequences – Noxious Weeds

Lower West Fork Project Final EIS 3.9-11

Watershed Projects

Decommissioning and storing 23 and 19 miles of road, respectively, would further reduce the potential of 

weed spread along road corridors. 

C. Cumulative Effects

The cumulative effects analysis area for noxious weeds is the entire Lower West Fork analysis area. This 

area was chosen because its past/present/future activities in this area have the potential to contribute to the 

spread of noxious weeds into areas not previously infested. (See also Sensitive Plants cumulative effects.) 

Past management activities and activities on private land have increased the noxious and non-native plant 

populations in the Lower West Fork analysis area. Road construction, livestock grazing, timber harvest, 

fire suppression activities, mining, housing developments, off-road vehicle use, and increased recreation 

use have all contributed to the spread of weeds. Under the no action alternative, no management activities 

related to this project would occur that would potentially spread weeds. However, that does not imply that 

weed infestations would decrease. Fuels would continue to increase from fire suppression, which would 

leave some areas at high risk of high severity burns in the event of wildfires, as occurred during the 

wildfires of 2000. There would be a high probability that weeds would spread to new areas, as also 

occurred after the wildfires of 2000 (see discussion above).

Alternative 1, No Action Alternative 

The cumulative effects analysis for the Proposed Action under Threatened, Endangered, and Sensitive Plant 

Species covers much of the information relevant to noxious weeds since competition with weeds is one of 

the major threats to sensitive plant habitat. The activities proposed in the Lower West Fork project may 

contribute to the spread of weeds along roadsides and other open and/or disturbed areas. Mitigation 

measures are designed to prevent weed spread from occurring. Controlling the spread of noxious weeds 

along some of the West Fork District roads will continue with periodic herbicide treatments of roads as 

analyzed in the 1998 Noxious Weed Environmental Assessment (PF-NOX-002). Spot treatment of weeds 

in the grasslands at the head of Piquett Creek from north of Shook Mountain to Medicine Point will 

continue as analyzed in the 2003 Noxious Weed Environmental Impact Statement (USDA Forest Service 

2003a). In addition, herbicide treatments are proposed for some of the units and roads within the Lower 

West Fork Project where they overlap with the Selway-Bitterroot Wilderness Invasive Plants Management 

Draft EIS (USDA Forest Service 2008). Units included in the Selway-Bitterroot Wilderness Invasive 

Plants Management analysis would likely only be treated if new invaders are found or if monitoring finds 

noxious weeds encroaching into previously weed-free areas. 

Alternative 2, Proposed Action

The cumulative effects analysis for Alternative 3 under Threatened, Endangered, and Sensitive Plant 

Species covers much of the information relevant to noxious weeds since competition with weeds is one of 

the major threats to sensitive plant habitat. Weed treatments will continue as described above under 

Alternative 2, Proposed Action. 

Alternative 3

3.9.7 CONSISTENCY WITH THE FOREST PLAN AND OTHER REGULATIONS

All alternatives would be consistent with the Forest Plan noxious weed goal. Mitigation measures and 

timber sale contract clauses require all machinery to be cleaned prior to entering the project area. All 

ground-disturbing activities are required to follow certain weed prevention methods as outlined in the 

Noxious Weed supplement to FSM 2080 (PF-NOX-003). Winter, helicopter, or skyline cable harvest 

would reduce the risk of ground disturbance and weed spread. Summer tractor harvest increases the risk of 

weed spread. Skid trails in these areas would be revegetated as soon as feasible after harvest activities are 

completed, reducing the risk of weed encroachment into disturbed areas. The No Action Alternative is 
Affected Environment and Environmental Consequences – Noxious Weeds

3.9-12 Lower West Fork Project Final EIS

consistent with the Forest Plan goal mentioned above, as existing weed control efforts (PF-NOX-002, 

USDA Forest Service 2003a) are designed to protect resource values and prevent weed spread onto 

adjacent lands. 
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

Lower West Fork Project Final EIS 3.10-1 

3.10 THREATENED, ENDANGERED, AND SENSITIVE PLANT

SPECIES

3.10.1 INTRODUCTION

Three sensitive plant species occur within the Lower West Fork project area: dwarf onion (Allium parvum), 

Rocky Mountain paintbrush (Castilleja covilleana), and Lemhi penstemon (Penstemon lemhiensis). An 

evaluation of the possible effects from management activities was conducted for these species and their 

habitat. 

3.10.2 REGULATORY FRAMEWORK

The Endangered Species Act requires that the Forest Service conserve endangered and threatened species. 

The National Forest Management Act and Forest Service policy direct that National Forests be managed to 

maintain populations of all existing native plant and animal species at or above minimum population levels. 

A minimum viable population consists of the number of individuals adequately distributed throughout their 

range necessary to perpetuate the existence of the species in natural, genetically stable, self-sustaining 

populations. The Forest Service identifies species for which population viability is a concern as sensitive 

species. This category may include federal candidates (plants being studied by the U.S. Fish and Wildlife 

Service for listing as threatened or endangered), or plant species proposed for listing as threatened or 

endangered in the Federal Register (MNHP 2008). Sensitive species can also be species that the Montana 

Natural Heritage Program (MNHP) considers rare in Montana or is otherwise of potential concern. The 

Forest Service Manual requires that activities conducted on National Forests be reviewed for possible 

impacts on endangered, threatened, or sensitive species (FSM 2670). That review is the Biological 

Evaluation and consists of the narrative below as well as the table “Determination of Effects on Sensitive 

Species”. 

The U.S. Fish and Wildlife Service listed water howellia (Howellia aquatilis) on July 14, 1994. This is the 

only federally listed, threatened plant species in Montana that occurs on National Forests but is not known 

to occur on the Bitterroot National Forest. The Northern Region Sensitive Plant Species List (USDA 

Forest Service 2004a) identifies a number of plants for which population viability is a concern on each 

National Forest; 33 sensitive plant species occur on the Bitterroot National Forest.

3.10.3 AREA OF ANALYSIS

The sensitive plant analysis area is the same as the watershed analysis area in the Lower West Fork of the 

Bitterroot River. The Darby Ranger District bounds the analysis area on the north, and Wheeler and Castle 

Creeks of the West Fork River form the southern boundary. The analysis area extends west to the SelwayBitterroot Wilderness boundary and east to the Sula Ranger District.

3.10.4 EFFECTS ANALYSIS METHODS

The effects of proposed management activities on sensitive plant species were assessed by evaluating 

impacts to population numbers, habitat and population viability of these species at several geographic 

scales: 1) global range; 2) statewide range; 3) on the Bitterroot National Forest and; 4) within the project 

area. Information on individual species, their habitat, distribution, and known occurrences within the state 

comes from the MNHP. There is little, if any, information on the distribution of these species historically 

so cumulative effects are based on knowledge about habitat and similar species within the genus. More 

current information comes from monitoring sensitive plant populations for effects of management activities 

and wildfires. 

An evaluation of threatened, endangered, and sensitive plant species in the Lower West Fork analysis area 

was conducted. The MNHP database (MNHP 2008) and past Bitterroot National Forest plant surveys were 

reviewed for sensitive plant locations in the analysis area. Plant surveys had been conducted by Forest 
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

3.10-2 Lower West Fork Project Final EIS 

botanists as part of the Nez Perce Fork Vegetation Management Environmental Assessment (1996-98), the 

Frazier Interface Environmental Assessment (2002), and the School Point Ecoburn (2005). The project 

area was also assessed for inclusion of habitat that might be suitable for other sensitive plant species by 

reviewing timber stand data and aerial photo interpretation. 

Bitterroot National Forest botanists conducted field surveys in areas not previously surveyed for sensitive 

plants known or that have the potential to occur in or near the Lower West Fork analysis area (Table 3.10-

1). Surveys were conducted in the spring and summers of 2005 – 2008. Dwarf onion, Rocky Mountain 

paintbrush, and Lemhi penstemon were the only sensitive plant species found during the field surveys. 

Table 3.10-1: Sensitive Plants That May Occur in the Lower West Fork Analysis Area 

*Taxonomic studies on herbarium specimens from Montana locations have determined the species Orogenia 

fusiformis (turkey-peas) is actually Orogenia linearifolia (Great Basin Indian-potato). Great Basin Indian-potato will 

be taken off the USDA Forest Service Sensitive Plant List for Montana in the fall of 2009. 

3.10.5 EXISTING CONDITION

A. Dwarf Onion (Allium parvum)

Dwarf onion is associated with grasslands, sagebrush and openings in ponderosa pine (Pinus ponderosa) 

stands, usually in exposed areas with sandy or gravelly soil. Bitterroot (Lewisia rediviva) is found in 

similar habitat and the two species may be seen growing together. The greatest threat to dwarf onion plants 

and habitat is spotted knapweed (Centaurea biebersteinii {C. maculosa}) encroachment, along with other 

weeds like cheatgrass (Bromus tectorum) and sulfur cinquefoil (Potentilla recta) that often invade spotted 

knapweed infested slopes. Weeds currently encroach on dwarf onion habitat and compete with the plants. 

Ultimately, this could adversely affect the viability of the dwarf onion population in the Lower West Fork. 

It is highly likely that the small size of existing populations is from competition with spotted knapweed.

Fifteen populations of dwarf onion were found within or near eight proposed units of the Lower West Fork 

project. Units 3, 18, 41, 63B, 64 (3 populations), 68, 69, 70, 73, and 74 contain 10 dwarf onion 

populations, two of which cross borders between units. The other five populations are north of unit 12, 

north and east of unit 64, east of unit 14, in the Steep, Applebury and Pine Creek areas, and along a ridge 

east of Frazier Draw. 

There are over 40 occurrences of dwarf onion in Montana, all but one of these on the Bitterroot National 

Forest. The other occurrence is located on Bureau of Land Management lands near Dillon. Most of the 

Bitterroot National Forest populations are on the south end of the Forest on the West Fork and Sula Ranger 

Districts with a few populations just to the north on the southern end of the Darby Ranger District. 

Populations are usually small, with less than 200 individuals. However, the area above Reimel Creek going 

Scientific Name Common Name Scientific Name Common Name

Ageratina occidentalis western boneset Idahoa scapigera scalepod

Allium acuminatum tapertip onion Mimulus nanus dwarf purple monkeyflower 

Allium parvum dwarf onions Orogenia linearifolia* Great Basin Indian-potato

Athysanus pusillus sandweed Penstemon lemhiensis Lemhi penstemon

Castilleja covilleana Rocky Mountain paintbrush Penstemon payettensis Payette penstemon 

Cypripedium parviflorum yellow lady's-slipper Tonestus aberrans Idaho goldenweed

Epipactis gigantea giant helleborine Trifolium eriocephalum woolly-head clover

Glossopetalon spinescens var. 

aridum spiny greenbush Trifolium gymnocarpon hollyleaf clover

Halimolobos perplexa puzzling rock cress Veratrum californicum California false hellebore 

Heterocodon rariflorum western pearl-flower 
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

Lower West Fork Project Final EIS 3.10-3 

up to Gibbons Pass contains an extensive metapopulation, most likely due to the extensive grasslands in the 

area. Dwarf onion is on the periphery of its range, which extends from eastern Oregon to California, east to 

Idaho, Nevada, and southwest Montana. Species on the periphery of their range have often adapted to 

habitats different from those in the main species range and may be important for overall species viability as 

environmental changes occur, such as global warming (Lesica and Allendorf 1995). Therefore, although it 

appears the Lower West Fork dwarf onion population is healthy, it is important to maintain the viability of 

this genetically isolated population. 

B. Rocky Mountain paintbrush (Castilleja covilleana)

Rocky Mountain paintbrush is associated with open, rocky areas at higher elevations, and in open 

ponderosa pine stands and grasslands at lower elevations. It is a regional endemic, occurring only in 

central Idaho and western Montana. There are 22 known occurrences in Montana, all located on the 

southern end of the Bitterroot National Forest. Threats to populations are from spotted knapweed 

encroachment and fire. 

Eight populations of Rocky Mountain paintbrush were found in the Lower West Fork analysis area. Two 

populations occur in unit 6 and unit 70. The other six populations are south of unit 32, east of units 10 and 

11, north of Beavertail Creek, along a ridge east of Frazier Draw, and in the vicinity of units 92 and 93. 

Harsh paintbrush (Castilleja hispida) has similar morphological characteristics to Rocky Mountain 

paintbrush and has been monitored since 1994. The population size has fluctuated in the fourteen years of 

monitoring, and monitoring since the fires in 2000 indicates that this species is slow to respond to a natural 

fire event (USDA Forest Service 2003b). 

C. Lemhi penstemon (Penstemon lemhiensis)

Lemhi penstemon is found on open, east to southwest facing slopes in grasslands, open ponderosa pine or 

Douglas-fir stands, and often associated with big sagebrush (Artemisia tridentata var. vasseyana) and 

bitterbrush (Purshia tridentata). It is a regional endemic, found only in southwestern Montana and 

adjacent Lemhi County, Idaho. Elevations range from 3200-8100 feet (Elzinga 1997). There are 90 known 

occurrences in Montana, 26 of which are located on the Bitterroot National Forest. Two of these 

occurrences are within the Lower West Fork analysis area. Many populations are small, only six on the 

Bitterroot Forest have over 100 individuals. Lemhi penstemon may be a recently evolved hybrid, which is 

why it is able to occupy a variety of habitats. Spotted knapweed encroaches on most of the Lemhi 

penstemon sites on the Bitterroot National Forest, particularly in areas that burned. Fire appears to be 

critical to Lemhi penstemon survival, which also favors weed encroachment.

Monitoring three Lemhi penstemon populations in Beaverhead County over a six-year period demonstrates 

population trends are closely tied to the existence of a seed bank (Heidel and Shelly 2001). Seeds appear to 

remain viable for at least six years and germination occurs during years of high moisture and disturbances 

such as fire. This determination concurs with recent monitoring on the Bitterroot National Forest. 

Botanists noted an increase in Lemhi penstemon during the wet summers of 1993 and 1995, and for three 

years after the fires of 2000, hundreds of seedlings germinated from a population that had burned during 

the fire (USDA Forest Service 2003b). 

The MNHP ranks Lemhi penstemon as G3/S2, which means that the species is potentially at risk globally 

and at risk in Montana due to limited occurrences and vulnerability to extirpation in the state. A 

conservation strategy for Lemhi penstemon was prepared in 1997 and lists threats to the species from 

grazing, mining, road maintenance and reconstruction, timber harvest, noxious weed encroachment, 

herbicide application, fire suppression, interaction of weed infestation and prescribed fire, and small 

population sizes (Elzinga 1997). 
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

3.10-4 Lower West Fork Project Final EIS 

There are four populations of Lemhi penstemon in the Lower West Fork project area. Two of these are 

located along roads within units 22 and 66; the other two are located on a hillside across from the Trapper 

Creek Job Corp Center and east of Gemmel Creek. 

D. Sensitive Plant Habitat

Sensitive plant habitat for the species listed in Table 3.10-1 exists in the Lower West Fork project area but 

only dwarf onion, Rocky Mountain paintbrush, and Lemhi penstemon were found during surveys. Most of 

the species in the table are known to occur on the Bitterroot National Forest. Payette penstemon, puzzling 

rockcress, tapertip onion, dwarf purple monkeyflower, Great Basin Indian-potato, and hollyleaf clover are 

all found in habitats similar to Lemhi penstemon and Rocky Mountain paintbrush. Great Basin Indianpotato and hollyleaf clover also occur in Douglas-fir/pinegrass (Pseudotsuga menziesia/Calamagrostis 

rubescens) habitats. Woolly-head clover has been found in mixed conifer stands on the West Fork District. 

All these habitats exist in the analysis area. 

Yellow lady’s-slipper, giant helleborine and California false hellebore are associated with riparian areas. 

Yellow lady’s-slipper has never been found on the Bitterroot National Forest. Giant helleborine occurs 

along the Salmon River in the Frank Church-River of No Return Wilderness, and two populations of 

California false hellebore were found along the Sapphire Divide. 

Sandweed, scalepod and western pearl-flower are associated with vernally moist rocky areas or swales. 

There are minor amounts of suitable habitat in the project area.

Finally, Idaho goldenweed and spiny greenbush have been found in crevices of granitic rock outcrops on 

the West Fork District. A small amount of this type of habitat exists in the project area. 

E. Species of Potential Concern

Previous field surveys identified populations of candystick (Allotropa virgata) in the Lower West Fork 

project area. None of these populations are within proposed treatment units. Candystick usually occurs in 

mature, open lodgepole pine stands in the subalpine fir/beargrass (Abies lasiocarpa/ Xerophyllum tenax) 

habitat type. In October 2004, the Forest Service removed candystick from the Northern Region Sensitive 

Plant List because the MNHP no longer tracks it as a Species of Concern (MNHP 2008). They consider 

candystick population numbers and distributions stable. The MNHP tracks it as a Species of Potential 

Concern and data on populations found after October 2004 are still entered into their database. 

Western mountain synthyris (Synthyris missurica) is another species of potential concern known to occur in 

the project area. However, no populations occur within treatment units. It occurs in subalpine forests and 

is found in the western states of California, Oregon, Washington, Idaho and Montana. Montana is on the 

periphery of its range. 

F. Species of Interest

A population of bitterroot occurs in unit 64 near the dwarf onion population. Bitterroot is a species of 

interest on the Bitterroot National Forest because they are important culturally to the Salish and Kootenai 

tribes, and are the Montana state flower. Bitterroot is often found in habitat similar to habitats occupied by 

dwarf onion and are also threatened by spotted knapweed encroachment. 

G. Sensitive Plant Species Excluded from Analysis

Table 3.10-2 lists sensitive plant species not considered in this analysis and the reasons they were excluded.

H. Boulder Creek Research Natural Area

The Boulder Creek Research Natural Area (RNA) is located within the Lower West Fork project area. It 

was established in 1991 to represent the Douglas-fir/globe huckleberry (Pseudotsuga menziesii/Vaccinium 

globulare), Douglas-fir/ninebark (P. menziesii/Physocarpus malvaceus), and subalpine fir/queencup
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

Lower West Fork Project Final EIS 3.10-5 

Table 3.10-2: Sensitive Plants Not Considered in the Lower West Fork Analysis

beadlily (Abies lasiocarpa/Clintonia uniflora) habitat types in the Northern Region of the Forest Service. 

The establishment record states that the “Boulder Creek RNA supports outstanding examples of the 

ponderosa pine (Pinus ponderosa) cover type in young and old-growth condition” (PF-SILV–013). 

Elevations in the RNA range from 4600 feet at Boulder Creek up to 7753 feet at the Boulder Point 

Lookout. About 30% of the Boulder Creek RNA is dominated by ponderosa pine; 20% by Douglas-fir, 

often in combination with ponderosa pine; 10% is riparian forests containing subalpine fir, Engelmann 

spruce (Picea engelmannii) and some grand fir (Abies grandis); 30% is talus and rock cliffs; and the 

remaining 10% is whitebark pine (Pinus albicaulis), mixed with subalpine fir and lodgepole pine (Pinus 

contorta). 

Management objectives for the Boulder Creek RNA include retaining the old-growth forest represented in 

upland and riparian habitat types and maintaining the high water quality of Boulder Creek. The 

establishment record recognized the occurrence of both fire-dependent old-growth ponderosa pine forest 

and fire-sensitive old-growth spruce-fir and grand-fir forests. It noted that maintaining old-growth 

ponderosa pine would require “special attention” and wilderness fire management policies would apply in 

the wilderness portion of the RNA. It also noted that fire suppression would be required to maintain the 

old-growth spruce-fir and grand fir forests along Boulder Creek (PF-SILV–013). 

3.10.6 ENVIRONMENTAL CONSEQUENCES

A. Effects Common to All Action Alternatives

The action alternatives harvest timber and underburn lower elevation slopes. These management practices 

would reduce fuel loads and open the forest canopy, which would improve sensitive plant habitat. 

However, these same practices would facilitate the spread of noxious weeds, especially spotted knapweed 

on south or west-facing slopes (See Section 3.8). Spotted knapweed outcompetes native plant species

reducing native plant populations and diversity, sometimes by as much as 60 to 90 % (Duncan 1997). Rare 

and sensitive plant species would be particularly vulnerable since there are fewer populations and 

individuals in the populations. 

Species Reason for Exclusion

Sapphire rockcress (Arabis fecunda)

Restricted to calcareous soils, which are not present in the 

project area. Only known locations in the Bitterroot 

area are on private land in the foothills of the 

Sapphires, west of Skalkaho Pass.

Poor sedge (Carex paupercula)

English sundew (Drosera anglica)

Crested shield-fern (Dryopteris cristata)

Primrose monkeyflower (Mimulus primuloides)

Pod grass (Scheuchzeria palustris)

Three-angled thread moss (Meesia triquetra)

Poor sedge, English sundew, crested shield fern, and pod 

grass are associated with fens and bogs. Poor sedge 

was taken off the Montana sensitive plant list in 2004, 

but is still listed for the Idaho side of the Bitterroot 

National Forest. No fens or bogs are known to occur 

in the Lower West Fork project area and, if there are 

any found, they will be protected by RHCAs. 

Idaho douglasia (Douglasia idahoensis)

Idaho douglasia is an alpine or subalpine species only 

known to occur on the Idaho side of the Bitterroot 

National Forest. It has never been found in Montana. 

Rough fleabane (Erigeron asperugineus) 

Evermann fleabane (Erigeron evermannii)

Discoid goldenweed (Haplopappus macronema var. 

macronema)

Bitterroot bladderpod (Lesquerella humilis)

Storm saxifrage (Saxifraga tempestiva)

Old man’s beard (Nodobryoria subdivergens)

All of these species are alpine species and there is no 

alpine habitat within the Lower West Fork project area. 
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

3.10-6 Lower West Fork Project Final EIS 

Dwarf onion, Rocky Mountain paintbrush, and Lemhi penstemon are all adapted to open, dry ponderosa 

pine habitat types. Lemhi penstemon is also adapted to the moister mixed ponderosa pine/Douglas-fir 

habitats. These habitat types burned historically at 5 to 25 year intervals (USDA Forest Service 1995). 

Fire suppression has increased the fire interval to about 50 years, creating higher fuel loads and the 

potential for high severity fires. The fire interval in the Lower West Fork area has been over 50 years 

(Section 3.2). 

Spotted knapweed is highly adapted to disturbance and open canopies, particularly on drier sites (Zouhar 

2001). Spotted knapweed also appears to thrive and spread to new areas following wildfire; particularly 

after high severity burns (Sutherland 2003, Ferguson et al. 2007) (see Section 3.8). In Douglas-fir habitats, 

disturbance is a prerequisite for spotted knapweed infestation (Ferguson et al. 2007). 

Other weeds encroach in these habitats following fire but are not as competitive as spotted knapweed for 

sensitive plant habitat. Bull thistle (Cirsium vulgare) was observed in many burned areas within a couple 

of years of the fires of 2000 (Sutherland 2005). It tends to be a short-lived plant and should decline as 

native vegetation recovers (Zouhar 2002a). Cheatgrass was also observed after the fires of 2000, especially 

under ponderosa pine trees where needle litter, often several inches thick, had burned off (personal 

observations). On north and east-facing sites not previously infested with weeds, native vegetation was 

recovering well enough to compete with any potential new invaders (personal observations). Ferguson et 

al. (2007) confirmed this observation when they noted that west-facing slopes were the most prone to 

spotted knapweed invasion. 

The potential to spread spotted knapweed would be less, especially in Douglas-fir habitats, in units treated 

by timber harvest or prescribed fire than on units that receive both treatments. However, without reducing 

fuels prior to burning there would be a greater potential for the fire to carry into the forest canopy and burn 

hotter. Ground-based timber harvest activities increase the risk of weed spread by scarifying the soil and 

potentially carrying weed-seed to the project area on equipment. Timber harvest using tractor equipment 

would occur on 34 percent of the harvest unit area and skyline cable would be used on 48 percent of the 

harvest area, the remaining 18 percent of the area in harvest units would not be harvested. Tractor harvest 

increases the risk of introducing or spreading invasive plant species because it typically disturbs some soil 

in the harvest unit (see Section 3.8) and more soil than skyline cable systems. The potential is higher that 

weeds would spread on lower elevation (below 6500 feet), south and west-facing aspects, where the most 

suitable weed habitat exists and the majority of activities are proposed. Underburning after harvest further 

increases the potential to open the canopy and create more bare soil. 

The proposed activities would reduce fuels and burn the slash and understory vegetation under controlled 

conditions, which would leave some of the native plant community intact and able to compete with weeds. 

By contrast, a potentially severe natural fire burning in the drier summer months (see Section 3.8) would 

destroy more of the native plants and provide a competitive edge to noxious weeds. Prescribed fires will 

most likely be ignited under cool conditions, which would achieve low to mixed fire severities. Low 

severity burns would be prescribed for most of the units and mixed severity burns would be prescribed in 

Units 32, 33, and the upper end of Unit 61. Fuel reduction activities would occur before the prescribed fire 

to control the burn severity. It would be more difficult to return to a pre-invasive plant fire regime in plant 

communities that contain a high stocking of noxious weeds (Brooks et al. 2004). 

Research from the fires of 2000 on the Bitterroot National Forest indicate that high severity fires are more 

conducive to weed spread than low severity fires in Douglas-fir habitats (Ferguson et al. 2007). Ponderosa 

pine habitats tend to already have established spotted knapweed populations, which will continue to be 

present in these habitats, with or without new disturbance (Ferguson et al. 2007). Research on the effects 

of prescribed fire on sulfur cinquefoil show similar results: hotter fall burns were more likely to increase 

sulfur cinquefoil and damage native grass species than cooler spring burns (Lesica and Martin 2003). 

Prescribed burning experience in Sequoia and Kings National Parks indicated that as fire severity 

increased, cheatgrass populations expanded so burning had to be discontinued (Rice 2003). 
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

Lower West Fork Project Final EIS 3.10-7 

B. Direct and Indirect Effects

Management of timber, fuels, and hydrology would not change under Alternative 1, No Action alternative. 

Alternative 1 would have no direct effects on individual sensitive plants, their habitat, or population 

viability. Dwarf onion and Lemhi penstemon are adapted to frequent, low to moderate severity fires (Arno 

1976). Dwarf onion has an underground bulb and Lemhi penstemon has a deep taproot both of which 

survive the types of fires that historically burned through grasslands, open ponderosa pine, and dry to 

moderately dry Douglas-fir stands in this area. However, fire suppression has increased fuel loads leading 

to more severe fires. These higher severity fires burn more of the duff and soil and increase the possibility 

of damaging the below ground plant tissue. A higher severity fire is also more likely to create large areas 

of bare soil and increase the spread of spotted knapweed and other noxious weeds (Sutherland 2003, 

Section 3.8). 

Alternative 1, No Action 

Dwarf onion, Rocky Mountain paintbrush and Lemhi penstemon were found within treatment units, but 

there is a large amount of potentially suitable habitat for Great Basin Indian-potato, hollyleaf clover, 

woolly-head clover, Payette penstemon, taper-tip onion, dwarf purple monkey-flower, and puzzling 

rockcress (Table 3.10-3). Minor amounts of suitable habitat exist for scalepod, sandweed, and western 

pearl-flower in many units. These species are associated with vernally moist areas that would be avoided 

during harvest activities. In addition, suitable habitat for riparian associated species like yellow lady’sslipper, giant helleborine, and California false hellebore is present in many units. This habitat would be 

avoided during project implementation, except for culvert replacement or removal activities. 

Alternative 2, Proposed Action

Effects on Sensitive Plants

Dwarf onion is present in Units 3, 18, 41, 63b, 64, 68, 69, 70, 73, and 74. Units 3, 18, 41, and 68 would be 

commercially thinned using skyline and tractor yarding systems, followed by prescribed fire. Prescribed 

fire with some manual thinning would be the only treatments in Units 63B, 64, 69, 70, 73, and 74. 

Dwarf onion (Allium parvum)

Mitigation measures to avoid dwarf onion plants and prevent noxious weed spread would prevent negative 

effects on dwarf onion plants, populations, and their habitat (Mitigation, Chapter 2). Dwarf onion flowers 

in late spring and early summer and are not easily observed after going to seed. Dwarf onion plants would 

be identified on the sale area map using GPS technology. Skid trails and cable corridors would be located 

to avoid known dwarf onion populations during harvest. These mitigations would avoid multiple passes 

with tractor or cable yarding equipment, which would damage underground dwarf onion bulbs. 

Treating these units would improve dwarf onion habitat by removing forest encroachment and opening the 

canopy. However, scheduling the prescribed fires would be problematic because burning in spring has a 

high probability of damaging above ground plant parts but burning in fall has a high risk of spreading 

spotted knapweed and cheatgrass. Weed prevention measures would be imperative to treating these units 

since spotted knapweed is present in all the units and cheatgrass is in Units 3, 18, 63B, 64, 68, 69, 70 and 

74. To prevent weed spread, bare soil will be seeded and fertilized per contract specifications. In addition, 

harvest equipment that would leave the roads would be washed before arriving on the site to prevent the 

transport of weed seed from other areas (Mitigation Measures Chapter 2 and contract specifications). If 

post-treatment monitoring indicates noxious weeds are moving into previously uninfested areas then spot 

herbicide treatments will be applied, avoiding directly spraying dwarf onion plants. 

No temporary roads are proposed within any of these units, but a tracked line machine (TLM) path is 

proposed for an area in Unit 3 where no dwarf onion occurs. 
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

3.10-8 Lower West Fork Project Final EIS 

Table 3.10-3: Sensitive Plants and Sensitive Plant Habitat by Unit in the Lower West Fork Project Area

1

H – Suitable habitat present; h – Some suitable habitat present; P – Sensitive plant Present; A - Adjacent to unit

Rocky Mountain paintbrush was found in units 6 and 70, and adjacent to the northeast border of unit 11. 

Unit 6 is proposed for commercial harvest using skyline and tractor harvest methods, and non-commercial 

thinning followed by prescribed fire. Unit 11 would be yarded using skyline cable, followed by prescribed 

Rocky Mountain paintbrush (Castilleja covilleana) Unit Alternative (s) Dwarf onion Rocky Mountain paintbrush Lemhi penstemon Great Basin Indian- potato Payette penstemon Hollyleaf clover Woolly-head clover Puzzling rockcress Taper-tip onion Dwarf purple 

monkeyflower

UnitAlternative (s)Dwarf onionRocky Mountain 

paintbrush

Lemhi penstemonGreat Basin IndianpotatoPayette penstemonHollyleaf cloverWoolly-head cloverPuzzling rockcressTaper-tip onionDwarf purple 

monkeyflower

1 2,3 H1 H H H H H H H H H 61a 2,3 h h h H h H H h h h

2 2,3 h h h H h H H h h h 62 2,3 H H H H H H H H H H

3 2,3 P h h H h H H h h h 63 2,3 h h h H h H H h h h

4 2,3 h h h H h H H h h h 63B 2,3 P h h H h H H h h h

5 2,3 H H H 64 2,3 P H H H H H H H H H

6 2,3 H P H H H H H H H H 65 2,3 H H H H H H H H H H

7 2,3 h h h H h H H h h h 66 H H P H H H H H H H

8 2,3 h H h H h H H h h h 68 2,3 P H H H H H H H H H

9 2,3 h h h H h H H h h h 69 2,3 P H H H H H H H H H

10 2,3 H H H H H H H H H H 70 2,3 P P H H H H H H H H

11 2,3 h A h H h H H h h h 71 2 H H H H H H H H H H

12 2,3 h h h H h H H h h h 72 2 H H H H H H H H H H

13 2 H H H 73 2 P H H H H H H H H H

14 2,3 H H H 74 2 P H H H H H H H H H

15 2 H H H 75 2,3 H H H

16 2 H H H 80 2,3 H H H

18 2 P H H H H H H H H H 81 2,3 H H H

19 2 H H H H H H H H H H 82 2,3 h h h H h H H h h h

20 2 H H H 83 2,3 H H H H H H H H H H

21 2,3 H H H 84 2,3 H H H H H H H H H H

22 2 H H P H H H H H H H 85 2 H H H H H H H H H H

23 2 H H H 86 2,3 H H H H H H H H H H

24 2 H H H H H H H H H H 87 2 H H H

25 2,3 h h h H h H H h h h 88 2,3 H H H

26 2 H H H 89 2,3 H H H

27 2,3 h h h H h H H h h h 90 2,3 H H H

28 2 H H H 91 2 H H H

29 2 H H H H H H H H H H 92 2 h h h H h H H h h h

32 2,3 H H H 93 2 h h h H h H H h h h

33 2,3 h h h H h H H h h h 94 2 h h h H h H H h h H

34 2,3 H H H H H H H H H H 95 2 H H H

35 2,3 H H H 96 2 H H H

40 2 H H H H H H H H H H 97 2 H H H

41 2 P h h H h H H h h h 98 2 h h h H h H H h h H

42 2 h h h H h H H h h h 99 2,3 H H H

60 2 h h h H h H H h h h 100 2,3 H H H H H H H H H H

60a 2,3 H H H H H H H H H H 101 2,3 H H H

61 2,3 H H H H H H H H H H 102 2 H H H
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

Lower West Fork Project Final EIS 3.10-9 

fire. Unit 70 would be treated using prescribed fire with some manual thinning in the southern part of the 

unit. All these units contain spotted knapweed so it will be important to practice proper weed prevention 

methods to reduce the risk of spread (see Mitigation Measures in Chapter 2).

Effects would be similar to those for dwarf onion (above); however, Rocky Mountain paintbrush occupies 

areas with more canopy cover than dwarf onion. Opening the canopy would benefit Rocky Mountain 

paintbrush but timber harvest and prescribed burning also increase the risk of spreading invasive plant 

species. If post-treatment monitoring indicates noxious weeds are moving into previously uninfested areas, 

then spot herbicide treatments will be applied, avoiding directly spraying Rocky Mountain paintbrush 

plants. 

Because Rocky Mountain paintbrush is morphologically similar to harsh paintbrush, we expect it would 

react similarly to wildfire, timber harvest, or prescribed fire. Information in the PLANTS database (USDA,

NRCS 2008) and monitoring data indicate that harsh paintbrush (and by inference, Rocky Mountain 

paintbrush) may be less tolerant of fire than other paintbrush species. Harsh paintbrush population sizes 

fluctuated between 1994 and 2008. In 2000, fire burned the monitoring site at low to moderate severity. 

Paintbrush numbers decreased from the year prior (1999) and the numbers decreased again by half in 2002. 

Plant density reached its lowest level since 1995 in 2003. Between 2003 and 2008, paintbrush numbers 

have remained about the same. Population fluctuations may also be due to other factors such as climate or 

noxious weed competition. Noxious weed seedlings initially increased in the monitoring plot since the fire, 

but have leveled off since 2004. Rocky Mountain paintbrush populations would be identified on the sale 

area map using GPS technology so skid trails or cable corridors would avoid known populations, and to 

prevent the accumulation of slash on or near them. By removing larger fuels prior to burning, the impacts 

on Rocky Mountain paintbrush plants and paintbrush habitat would be minimized. 

There are no temporary roads or TLM paths proposed in units 6 or 70.

Lemhi penstemon was found in road cuts within units 22 and 66. Commercial thinning using tractor 

yarding and non-commercial thinning followed by prescribed fire are proposed in Unit 22. Unit 66 would 

be treated using prescribed fire only; there would be no fuels treatment before ignition. 

Lemhi penstemon (Penstemon lemhiensis)

Effects would be similar to those for dwarf onion; however, Lemhi penstemon is a fire adapted species (see 

discussion in Affected Environment). Road cut populations that burned in Robbins Gulch during the fires 

of 2000 expanded up slope as hundreds of new seedlings appeared a year after the fire (personal 

observation). Studies done elsewhere confirm that fire releases dormant seed stored in the soil (seed bank) 

(Elzinga 1997; Heidel and Shelly 2001). Opening the canopy would benefit Lemhi penstemon but 

harvest/burning activities would increase the risk of spreading invasive plant species. Both of these units 

contain spotted knapweed and cheatgrass so it would be important to implement weed prevention 

mitigations (see Mitigation Measures in Chapter 2). If post-treatment monitoring indicates noxious weeds 

are moving into previously uninfested areas then spot herbicide treatments will be applied, avoiding 

directly spraying Lemhi penstemon plants. In addition, roadside spraying of NFSR 13423 and 5723 will 

avoid directly spraying over Lemhi penstemon plants located in the road cuts (see Mitigation Measures, 

Chapter 2). 

There are no temporary roads or TLM paths proposed in units 22 or 66.

Effects on Sensitive Plant Habitat

As noted in Table 3.10-3 above, all of the proposed units have suitable habitat for some sensitive plant 

species, though only a few species were found during field surveys. Most of the sensitive plants would 

benefit from the reduction in forest canopy and the re-introduction of frequent, low intensity fire. 

However, the treatments to achieve the objectives also have the potential to spread noxious weeds (Noxious 

Weeds Section 3.8). Careful layout and administration of skid trails and cable corridors would protect 

Effects of Harvest Activities
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

3.10-10 Lower West Fork Project Final EIS 

known sensitive plant populations within treatment units. Minimizing soil exposure and maintaining the 

understory vegetation would reduce the spread of noxious weeds. If soil and vegetation displacement are 

minimized and weed spread kept to a minimum, there would be no adverse impacts on potentially suitable 

sensitive plant habitat. Weed prevention mitigation measures (Chapter 2) need to be applied in all 

treatment units and especially those units with sensitive plants (units 3, 6, 18, 22, 41, 64, 66, 68, 69, 70, 73, 

74) and those infested with several noxious weed species (units 2, 10, 13, 21, 28, 89, 99). 

Seeding should only be done if harvest activities created large areas of bare soil. Seeding with commercial 

seed mixes increases the risk of introducing weed, or other unwanted seed on site, therefore all seed mixes 

must be approved by the Forest Botanist and be certified weed-free seed. 

Herbicide treatments may also be used if monitoring indicates that noxious weeds are spreading into 

previously uninfested areas. Spot herbicide treatments would be applied, avoiding directly spraying 

sensitive plants.

Temporary road and TLM trail prisms tentatively identified in units 1, 3, 8, 9, 12, 16, 20 35, 41, 61, 89, and 

99 were surveyed and no sensitive plants were found. Temporary roads and TLM trails would not 

adversely impact sensitive plants or their habitat. If sensitive plants are discovered during project 

implementation, the temporary roads or TLM trails would be relocated to avoid impacting plants. If 

changes in temporary road or TLM trail locations are needed during implementation, sensitive plant 

surveys would be conducted prior to approval. 

Temporary Roads and TLM Trails

Herbicides would be applied to temporary roads and TLM trails after completion of harvest and prior to 

rehabilitation and seeding. 

All of the units treated with prescribed fire have some potentially suitable sensitive plant habitat but 

sensitive plants were only found in units 64, 66, 69, 70, 73, and 74. Spotted knapweed also infests these 

units. 

Thinning and Prescribed Fire

Sensitive plant habitat in all the units would be adversely impacted if burning causes spotted knapweed, 

cheatgrass, and/or houndstongue to spread (see Section 3.8). However, we can manage fire severity using 

prescribed fire but wildfire severity would more likely be higher depending on conditions at the time of the 

fire. Opening up forest canopies, keeping ground cover and root systems intact, and preventing ground 

disturbance would favor the propagation of sensitive plants and limit the potential of spreading weeds. 

Spring burning would reduce the risk of a crown fire and weed spread, if it is completed before sensitive 

plants emerge. Above ground plant parts may be damaged, but the deep underground roots and bulbs of 

most of the sensitive plant species, Rocky Mountain paintbrush being the exception, would survive and 

resprout. Fall burning would mimic the natural fire regimes and may benefit sensitive plants more if 

invasive species do not increase. However, since species like spotted knapweed have already seeded by the 

fall, burning may favor spotted knapweed allow it to encroach further into sensitive plant habitat. 

If post-treatment monitoring indicates noxious weeds are moving into previously uninfested areas then spot 

herbicide treatments will be applied, avoiding directly spraying sensitive plants.

In general, the proposed watershed improvement projects would improve sensitive plant habitat by 

reducing the risk of noxious weed spread that occurs on open roads. Culvert replacement and removal 

occurs in previously disturbed areas and would not impact sensitive plants or their habitat. Roads would be 

ripped and seeded, which would inhibit the spread of invasive plants. Recontouring roads may adversely 

affect individual sensitive plants. With present funding those areas would only include about the first 50 

feet of road and areas where culverts would be removed. Lemhi penstemon is known to occur in road cuts 

along at least two roads in the Piquette Creek drainage and was found along NFSR 13423, which is 

Watershed Projects
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

Lower West Fork Project Final EIS 3.10-11 

proposed for storage and decommissioning. The area where Lemhi penstemon was found would only be 

put in storage so the plants would not be disturbed since they occur in the road cut. Other roads proposed 

for storage or decommissioning that had suitable sensitive plant habitat were surveyed (including NFSR 

13831 and portions of NFSR 13836 and 13838) and no sensitive plants were found. Surveys concentrate 

on the first 50 to 100 feet of road where recontouring will occur. 

Herbicide treatments would be applied to all roads proposed for storage or decommissioning prior to 

beginning obliteration work for easier access. Once these roads are closed, access would be by foot or 

horse. 

Restoration work on terraces would not impact sensitive plants since no sensitive plants were found on any 

terrace units. 

Species of Potential Concern

Several populations of candystick were found during surveys of the Lower West Fork project area. None 

of these populations are within proposed units. 

There are also scattered populations of western mountain synthyris within a mile east of unit 92 in the 

southern end of the project area. These plants would not be impacted by proposed activities. 

Effects on Sensitive Plants

Alternative 3

Dwarf onion was found in units 3 and 41 in Alternative 3. Effects on dwarf onion would be the same as 

described in Alternative 2. Effects on the dwarf onion population in unit 64 would be the same as under 

Alternative 1 since no treatments would occur under this Alternative.

Dwarf Onion (Allium parvum)

Rocky Mountain paintbrush was found in the same units as in Alternative 2. Effects would be the same as 

in Alternative 2. 

Rocky Mountain paintbrush (Castilleja covilleana) 

There would be no effects on Lemhi penstemon populations since units 22 and 66 would not be treated 

under Alternative 3. 

Lemhi penstemon (Penstemon lemhiensis)

Effects on Sensitive Plant Habitat

Effects of proposed commercial and non-commercial harvest activities on sensitive plant habitat would be 

the same as for Alternative 2 except there will be 735 fewer acres treated. This includes about 195 less 

acres of skyline harvest and about 540 fewer acres of tractor harvest. There is no way of predicting when 

and where a wildfire will occur, but without fuels treatment it would most likely burn at high severity. 

Noxious weeds and cheatgrass appear to have a competitive advantage over sensitive plants following high 

severity burns. Dwarf onion may be less adversely affected than Lemhi penstemon because it occurs in 

open areas which may not carry a hot fire. Lemhi penstemon occurs in ponderosa pine forests that 

accumulate more slash and burn hotter. 

Effects of Harvest Activities and Prescribed Fire

Alternative 3 would require similar amounts of temporary road and TLM trails to access timber as 

Alternative 2 and would have the same effects. Temporary roads would be ripped, obliterated, and 

revegetated, and TLM pads would be revegetated after use to prevent weed spread (as part of Standard 

Timber Sale Contract). 

Temporary Roads and TLM Pads

Alternative 3 would store an additional 0.6 miles of road, decommission another 17.2 miles, and remove 11 

more culverts than Alternative 2. Terrace restoration work would be the same as in Alternative 2. Effects 

Watershed Projects
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

3.10-12 Lower West Fork Project Final EIS 

on sensitive plants and their habitat for these projects would be the same as in Alternative 2, although the 

decommissioning or storage of more roads would aid in the reduction of weed spread along road corridors. 

If Alternative 3 is selected, NFSR 13430 and 13842 would need to be surveyed for sensitive plants prior to 

decommissioning or storage.

C. Cumulative Effects 

The cumulative effects analysis area for sensitive plants is the entire Lower West Fork project area. This 

area was chosen because its past/present/future activities have the potential to contribute to the loss of 

viable populations of sensitive plant species by impacting individual plants or their habitat. 

The extent to which dwarf onion, Lemhi penstemon and Rocky Mountain paintbrush populations and their 

habitat, have been impacted by past management activities is unknown. It is probable that more suitable 

habitat existed prior to fire suppression activities, in which case continued fire suppression would cause 

more forest encroachment on these historically open forest habitats. There was probably more suitable 

dwarf onion and Lemhi penstemon habitat prior to the introduction and spread of spotted knapweed. Road 

construction, past timber harvests, grazing, and ATV use in the area most likely contributed to the spread of 

spotted knapweed. Continued fire suppression and no fuel reduction in the Lower West Fork area would 

increase the risk of more severe fire events. As noted above in Effects Common to All Action Alternatives, 

high severity fires contribute to the spread of spotted knapweed on drier, south and west-facing aspects and 

favor cheatgrass spread. Fire suppression may be one of the main threats to Lemhi penstemon viability, 

which requires fires to release dormant seed stored in the soil (Elzinga 1997; Heidel and Shelly 2001). 

Off-road vehicles compromise sensitive plant viability by damaging or destroying the plants and their 

habitat and spreading weeds when they travel off-road. Off-road vehicles damaged a small population of 

Lemhi penstomen in the lower Robbins Gulch drainage and have spread spotted knapweed along the ridge 

above Piquett Creek leading to Shook Mountain (personal observation). This area has been analyzed for 

spot herbicide treatment and is being treated to keep weeds from spreading farther.

The fires of 2000 had variable effects on sensitive plants. A large number of Lemhi penstemon seedlings 

were observed in Robbins Gulch following the fires. However, dwarf onion and Rocky Mountain 

paintbrush did not show the same response and Rocky Mountain paintbrush may be negatively affected as 

described earlier in the effects analysis. Also as described earlier, spotted knapweed appeared to benefit 

from the fires by resprouting and increased seed germination. 

Fire suppression activities also affect sensitive plants because firelines are constructed to contain the fire 

and there is often not time or the opportunity to survey for sensitive plants beforehand. The ground 

disturbance created by hand or dozer fireline provides a seedbed for weeds. Grass seeding and restoration 

of firelines once the fire is controlled has reduced this avenue of weed spread. 

Under Alternative 1, the No Action Alternative, fuels would continue to increase and sensitive plant habitat 

would be encroached through stand succession and weed infestation. These effects may adversely impact 

some sensitive plant habitat but would not adversely impact the population viability of dwarf onion, Lemhi 

penstemon or Rocky Mountain paintbrush in the Lower West Fork area. The potential of a high severity 

wildfire increases with increasing fuel loads. A high severity wildfire would have a greater potential of 

damaging the underground roots and bulbs, and consuming the soil seed bank of sensitive plants. Sensitive 

plants would regenerate with increased competition from weeds, especially spotted knapweed and 

cheatgrass, which appear to be better adapted to high severity fires. Noxious weed spraying would 

continue on specific West Fork District roads, which would reduce weed competition in the road corridor. 

Alternative 1, No Action 

Under Alternative 2, the Proposed Action, the cumulative effects of the proposed treatments would restore 

sensitive plant habitat by opening encroached stands, reducing fuel loads, and increasing the opportunity 

Alternative 2, Proposed Action
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

Lower West Fork Project Final EIS 3.10-13 

for more frequent, low intensity fires. These conditions are similar to those the sensitive plants are adapted 

to, which would promote their propagation. Reintroducing fire would be particularly beneficial to Lemhi 

penstemon (see Effects Analysis for Lemhi penstemon). Associated with the proposed treatments is the 

potential of spreading weeds through ground disturbance. Under Alternative 2, the locations of ground 

disturbance would be planned and controlled. Mitigation measures would also be in place to reduce the 

risk of and prevent weed spread, and protect known sensitive plant populations (Chapter 2). Alternative 2 

should not adversely impact the population viability of dwarf onion, Rocky Mountain paintbrush, or Lemhi 

penstemon with the effective application of the mitigation measures. 

All of the present or foreseeable future actions proposed on the Bitterroot National Forest are required to 

maintain population viability and geographic distribution of all sensitive plant subpopulations occurring on 

the Bitterroot National Forest. The Lower West Fork project as described under this alternative would not 

reduce population viability of sensitive plant populations in the project area or contribute to the decline of a 

population elsewhere on the Bitterroot National Forest. The population viability of sensitive plants would 

not be adversely affected at the Forest level.

The cumulative effects of proposed activities in Alternative 3 would be similar to Alternative 2. All of the 

present or foreseeable future actions proposed on the Bitterroot National Forest are required to maintain 

population viability and geographic distribution of all sensitive plant subpopulations on the Bitterroot 

National Forest. The Lower West Fork project as described under this alternative would not reduce 

population viability of sensitive plant populations in the project area or contribute to the decline of a 

population elsewhere on the Bitterroot National Forest. The population viability of sensitive plants would 

not be adversely affected at the Forest level. 

Alternative 3

D. Determination of Effects for Sensitive Species 

BITTERROOT NATIONAL FOREST

SENSITIVE PLANT SPECIES BIOLOGICAL EVALUATION

 SUMMARY OF CONCLUSION OF EFFECTS

 Project Name: Lower West Fork Project

 District: West Fork Ranger District

SPECIES ALT 1

No Action ALT 2 ALT 3

Ageratina occidentale (western boneset) NI1 NI NI

Allium acuminatum (tapertip onion) NI MIIH MIIH

Allium parvum (dwarf onion) NI MIIH MIIH

Arabis fecunda (Sapphire rockcress) NI NI NI

Athysanus pusillus (sandweed) NI NI NI

Carex paupercula (poor sedge) (Idaho only) NI NI NI

Castilleja covilleana (Rocky Mtn. paintbrush) NI MIIH MIIH

Cypripedium parviflorum (yellow lady’s-slipper) NI NI NI

Douglasia idahoensis (Idaho douglasia) (Idaho only) NI NI NI

Drosera anglica (English sundew) NI NI NI

Dryopteris cristata (crested shield fern) NI NI NI

Epipactis gigantean (giant helleborine) NI NI NI
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

3.10-14 Lower West Fork Project Final EIS 

SPECIES ALT 1

No Action ALT 2 ALT 3

Erigeron asperugineus (rough fleabane) NI NI NI

Erigeron evermannii (Evermann’s fleabane) NI NI NI

Glossopetalon spinescens (green-bush) NI NI NI

Halimolobos perplexa (puzzling halimolobos) NI MIIH MIIH

Haplopappus macronema (discoid goldenweed) NI NI NI

Heterocodon rariflorum (western pearl-flower) NI NI NI

Idahoa scapigera (scalepod) NI NI NI

Lesquerella humilis (Bitterroot bladderpod) NI NI NI

Meesia triquetra (three-angled threadmoss -moss) NI NI NI

Mimulus nanus (dwarf purple monkeyflower) NI MIIH MIIH

Mimulus primuloides (primrose monkeyflower) NI NI NI

Nodobryoria subdivergens (old man’s beard – lichen) NI NI NI

Orogenia linearifolia (Great Basin Indian-potato) NI MIIH MIIH

Penstemon lemhiensis (Lemhi penstemon) NI MIIH MIIH

Penstemon payettensis (Payette penstemon) NI MIIH MIIH

Saxifraga tempestiva (storm saxifrage) NI NI NI

Scheuchzeria palustris (Pod grass) NI NI NI

Tonestus aberrans (Idaho goldenweed) NI NI NI

Trifolium eriocephalum (woolly-head clover) NI MIIH MIIH

Trifolium gymnocarpon (hollyleaf clover) NI MIIH MIIH

Veratrum californicum (California false hellebore) NI NI NI

 1

 NI = No Impact

 MIIH = May Impact Individuals or Habitat, but will not likely result in a trend toward Federal listing or 

 reduced viability for the population or species

 LIFV = Likely to Impact Individuals or Habitat with a consequence that the action may contribute towards 

 Federal listing or result in reduced Viability for the population or species (This determination triggers a 

 significant action)

 BI = Beneficial Impact

 Form 2 (R-1-2670-95)

Prepared by: /s/Linda Pietarinen Date: September 22, 2009

Bitterroot Forest Botanist

 

 LINDA PIETARINEN

3.10.7 CONSISTENCY WITH THE FOREST PLAN AND OTHER REGULATIONS

The Forest Plan specifies (Forest Plan, Chapter II, page 21) that vascular plants identified as rare, pending 

study, or proposed as threatened or endangered would be identified and protected. The plants termed 'rare' 

are the plants on the Regional Forester's sensitive species list, as well as any plants identified by the Forest 

as being of special concern. A stated goal of Forest Service policy is to maintain population viability over 

a species' geographic range. Information on the number of plants required for maintenance of viable 

populations is not available. Therefore, a conservative approach is required when determining the effects 

of management activities. Sensitive plant populations and their habitat would be protected by the effective 
Affected Environment and Environmental Consequences – Threatened, Endangered, and Sensitive Plant Species

Lower West Fork Project Final EIS 3.10-15 

application of the mitigation measures, and the proposed activities in all alternatives would be consistent 

with the Bitterroot National Forest Plan to reduce the risk of further weed spread.

All alternatives are consistent with NFMA requirements (used in the existing Bitterroot National Forest 

Plan) to maintain minimum viable populations of all existing native plant species. Alternatives 2 and 3 

contain mitigation measures that ensure these requirements would be met. 

All action alternatives and the no action alternative are consistent with the Endangered Species Act. None 

of the proposed activities in any alternative or the no action alternative would impact threatened or 

endangered plant species, since there are no threatened or endangered plant species known to occur on the 

Bitterroot National Forest nor were any found during Forest Service surveys over the last eighteen years.
Affected Environment and Environmental Consequences - Heritage

Lower West Fork Project Final EIS 3.11-1

3.11 HERITAGE 

3.11.1 REGULATORY FRAMEWORK 

The primary legislation governing cultural resource management is the National Historic Preservation Act 

(NHPA) of 1966 (amended in 1976, 1980, and 1992). All other cultural resource management laws and 

regulations support, clarify, or expand on the NHPA. Federal Regulations 36 CFR 800 (Protection of 

Historic Properties), 36 CFR 63 (Determination of Eligibility to the National Register of Historic Places), 

36 CFR 296 (Protection of Archaeological Resources), and Forest Service Manual 2360 (FSM 2360) 

provide the basis of specific Forest Service cultural resource management practices. These laws and 

regulations guide the identification, evaluation, and protection of cultural resources on National Forest. 

The Forest Service is required to consider the effects of agency actions on cultural resources that are 

determined eligible for the National Register of Historic Places (NRHP) or on cultural resources not yet 

evaluated for eligibility. The Secretary of Interior’s Guidelines for Archaeology and Historic Preservation

are also an important element of federal agencies’ management of cultural resources on public lands.

Several other laws address various aspects of cultural resource management on National Forests and 

include:

Ø National Environmental Policy Act of 1969 (NEPA)

Ø National Forest Management Act of 1976 (NFMA)

Ø Antiquities Act of 1906

Ø Historic Sites Act of 1935

Ø Archaeological Resource Protection Act (ARPA) of 1979, as amended in 1988

Ø Native American Graves Protection and Repatriation Act of 1990 (NAGPRA)

Ø American Indian Religious Freedom Act of 1978 (AIRFA)

ARPA, NAGPRA, and AIRFA describe the role of Native American tribes in the federal decision-making 

process, including heritage resource management decisions. ARPA requires tribal notification and 

consultation regarding permitted removal of artifacts from federal lands. NAGPRA recognizes tribal 

control of human remains and certain cultural objects on public lands and requires consultation prior to 

their removal. The AIRFA requires federal agencies to consider the impact of their actions on traditional 

tribal cultural sites. The NHPA also specifically calls for tribal participation in the NHPA Section 106 

consultation process.

The Confederated Salish and Kootenai Tribes of the Flathead Reservation regard the entire Bitterroot 

National Forest as an area of concern, and are consulted on all projects occurring within the National Forest

boundary. The Nez Perce Tribe has identified cultural concerns within the Selway River and West Fork 

Bitterroot watersheds, and within the corridor of the Nez Perce (Nee-Me-Poo) National Historic Trail. 

Consultation with the Confederated Salish and Kootenai Tribes of the Flathead Nation occurred on March 

31, 2008 and no tribal cultural concerns were identified in the Lower West Fork analysis area. 

3.11.2 AREA OF ANALYSIS

All National Forest lands within and immediately contiguous to the Lower West Fork project area 

boundaries comprise the cultural resource analysis area. 

3.11.3 EFFECTS ANALYSIS METHODS 

Heritage program specialists participate in the planning and analysis of proposed projects. Participation 

includes: 

1) review of historical materials, archival documents, and overviews relevant to the project area 

2) analysis of the nature of the project and its potential to affect cultural resources 

3) review of public concerns regarding the project and its potential effects
Affected Environment and Environmental Consequences - Heritage

3.11-2 Lower West Fork Project Final EIS 

4) consultation with interested tribes, heritage interest groups, and the Montana State Historic 

Preservation Office (MTSHPO) 

The Heritage specialist determines the project’s “area of potential effect” (APE) based on the geographic 

area in which a project may alter the character or use of any historic or traditional cultural properties.

The Heritage specialist determines whether existing cultural resource data is adequate to complete the 

environmental analysis and disclose potential cultural resource effects. Where additional inventory is 

needed, the heritage specialist designs a survey strategy to locate all historic properties within the area of 

potential effect based on criteria defined in “Site Identification Strategy Prepared for the Bitterroot, 

Flathead and Lolo National Forests”. Newly discovered cultural resources are recorded and their NRHP

eligibility status determined in consultation with the Montana State Historic Preservation Office 

(MTSHPO). Both background research and fieldwork are documented in a report submitted to the 

MTSHPO. The Heritage program manager consults with MTSHPO to determine the nature of the project’s 

effects on significant properties. The Heritage program manager, interested tribes, and MTSHPO work 

together to determine appropriate project redesign, restrictions, designation of sensitive areas, or mitigation 

measures when needed. The Heritage program manager coordinates recommendations, actions, and 

monitoring with the project leader, MTSHPO, and appropriate Tribal preservation officials.

Projects affect historic properties when they change the characteristics that qualify the historic properties

for inclusion to the NRHP. Depending on the property’s significant characteristics, its location, setting, or 

use may be relevant to the determination of effect. A project adversely affects an historic property when it 

diminishes the integrity of the historic property’s location, design, setting, materials, workmanship, feeling, 

or association. Criteria for determining adverse effects are described more fully in National Register 

Bulletin #15; How to Apply the National Register Criteria for Evaluation (U.S. Dept. of Interior 1995).

The Forest Service Heritage Program is responsible for management of cultural resources to prevent loss or 

damage before they can be evaluated for scientific study, interpretive efforts, or other appropriate uses. 

This requires projects to be implemented in a manner that avoids adverse effects on historic properties. 

Where a proposed project would result in impacts to historic properties, project design anticipates that 

treatment of the property will conform to sound preservation practice and be consistent with all applicable 

preservation standards. Project design ensures that the essential form and integrity of historic properties is 

not impaired. Appropriate mitigation treatments are determined in compliance with 36 CFR 800.5 when

potential adverse effects cannot be avoided. Mitigation measures for timber harvest may include requiring 

buffer zones or directional falling, changing harvest unit boundaries, and road or skid trail locations, and 

restricting harvest methods, season of operation, slash treatment, or tree planting activities. The Forest 

Service consults with tribal representatives to develop appropriate mitigation measures when a project 

potentially affects a property important to a tribe.

3.11.4 EXISTING CONDITION 

Since 1976, twenty-three archaeological surveys have been conducted in or within a half-mile of the project 

area. Professional cultural resource specialists conducted or supervised the inventories and complied with 

all applicable Federal standards. Surveys conducted since 1980 include the following projects:

Ø Beavertail Creek TS (80-BR-4-3)

Ø Pierce Creek TS (81-BR-4-2)

Ø Piquett TS (81-BR-4-6)

Ø Mud Basin TS (82-BR-4-2)

Ø Upper East Piquett TS (83-BR-4-3)

Ø Piquett Bottom TS (84-BR-4-3)

Ø Violet Removal TS (85-BR-4-3)

Ø Pierce Baker TS (86-BR-4-2)

Ø Castle II TS (87-BR-4-4)

Ø Buck-Little Boulder TS (91-BR-4-1)

Ø West Fork Wildlife Burns (92-BR-4-3)

Ø Kucera Hazard Reduction Model (92-BR-4-9)

Ø Piquett/Antler Release (93-BR-4-10)

Ø Christisen Creek Salvage (96-BR-4-2)

Ø Applebury Landing Road Access (97-BR-4-9)

Ø Thin Buck TS (98-BR-4-3)

Ø Wildfire 2000 Dozer Line CRI (00-BR-SO-1)

Ø Burned Area Recovery 2000 (01-BR-SO-1)
Affected Environment and Environmental Consequences - Heritage

Lower West Fork Project Final EIS 3.11-3

Ø Three-Forest SIS Survey (01-BR-SO-2)

Ø Frazier Draw Interface (02-BR-4-8)

Ø Steep/Applebury PCT/Underburn (03-BR-4-3)

Approximately 90% of the moderate-to-high probability terrain had been surveyed for cultural resources 

within or adjacent to the proposed project units prior to the 2008 field season. Sixteen cultural sites are 

known to exist within the project area, including lithic scatters, cambium-peeled trees, cabin ruins, and a 

lookout site. Two sites have been formally determined “Not Eligible” for the National Register in 

consultation with MTSHPO, one of which has been destroyed. Of the remaining thirteen sites, three are 

eligible for inclusion to the National Register – Boulder Point Lookout, Medicine Point Lookout and 2 

buildings at the West Fork Ranger Station. None of the three sites are within proposed treatment units or 

areas of potential effect. The remaining ten sites have not been evaluated and must be managed as 

“eligible” sites until a determination of eligibility is made. However, none of these sites are located within 

proposed treatment units or their area of potential effect.

The desired condition for cultural resources in the Lower West Fork analysis area would include the 

following: cultural resource inventory of 100% of all high probability terrain and a representative sampling 

of low-to-moderate terrain, as defined in the Bitterroot NF SIS; evaluation and determinations of eligibility 

for all known sites; and protection and preservation of all historic and traditional cultural properties. The 

existing condition of cultural resources in the Lower West Fork analysis area falls short of the desired 

condition. Although all previously unsurveyed moderate-to-high probability terrain has been inventoried 

for cultural resources, the eligibility status of ten known sites (all outside the current project APE) is 

currently undetermined.

3.11.5 ENVIRONMENTAL CONSEQUENCES

A. Direct and Indirect Effects

Direct and Indirect Effects

Alternative 1 (No Action)

Because no fuel reduction, timber harvest, road relocation or other proposed activities would occur under 

this alternative, there is no potential for direct effects to cultural resources resulting from these activities. 

Failure to reduce fuels would increase the risk of severe wildfire, and associated erosion and noxious weed 

infestations, destroying cultural sites within and around the project area. 

Direct Effects

Alternative 2 (Proposed Action)

Fuel reduction and timber harvest activities such as tree falling, skidding, decking, slash disposal, and 

underburning all present potential threats to cultural sites as do other activities such as landing and 

temporary road construction, or road relocation. However, extensive literature search (including review of 

previous surveys) and consultation with the Confederated Salish & Kootenai Tribal Preservation Officer 

have revealed no cultural sites or traditional cultural properties located within or in close proximity to any 

of this project’s proposed treatment units. Proposed watershed treatments involving culvert removal and 

replacement, road storage and decommissioning will occur within areas of previous disturbance. Project 

activities would have no direct effects on known cultural resources.

Indirect Effects

Many activities associated with the actions in this alternative, particularly that involving timber harvest, 

have the potential for indirect effects on cultural resources within the areas of potential effect, such as 

temporary auditory and visual disturbances.
Affected Environment and Environmental Consequences - Heritage

3.11-4 Lower West Fork Project Final EIS 

Direct Effects

Alternative 3

Because fewer acres are treated under Alternative 3, the potential for direct adverse effects on previously 

unknown cultural resources would be slightly lower than under Alternative 2. However, extensive survey, 

literature search and Tribal/SHPO consultation have revealed no cultural sites or traditional cultural 

properties within or in close proximity to the project’s proposed treatment units. Proposed watershed 

treatments involving culvert removal and replacement, road storage and decommissioning will occur within 

areas of previous disturbance. Project activities would have no direct effects on known cultural resources. 

Indirect Effects

Activities associated with the actions in this alternative have the potential for minor indirect effects on 

cultural resources within the areas of potential effect, such as temporary auditory and visual disturbances. 

B. Cumulative Effects

Prior to establishment of the Forest Service Heritage Program in 1976, timber harvest, reforestation, and 

trail, road, and recreational facility development occurred with little analysis of cultural resources impacts. 

Areas logged, roaded, terraced, or otherwise subjected to extensive ground disturbance or subsequent 

erosion experienced substantial cultural resource destruction. Other adverse effects occurred from 

livestock grazing, irrigation development, and dispersed recreation. Little or no effort was made to deter 

private collection of historic or prehistoric artifacts on National Forest lands, and losses of cultural 

resources were extensive in certain locations. While adoption and enforcement of federal cultural resource 

protection legislation and regulations over the past 30 years has reduced the rate of cultural resource 

deterioration, it is unrealistic to expect that deterioration could be completely eliminated.

Common to All Alternatives

Forest management practices over the past century, resulting in fuel accumulation, have contributed to the 

occurrence of intense, stand-replacing wildfire. While many types of cultural resources can survive lowseverity fires with little or no damage, high-severity burns destroy or damage a wide range of cultural sites 

and artifacts. Centuries-old cambium-peeled ponderosa pine trees marking many tribal trails and camping 

areas are an example. On the Bitterroot National Forest, many of these peeled trees survived a succession 

of low-intensity fires over the past 300 years, but were destroyed by the fires in 2000.

Plants important to the lives of the Bitterroot Salish, Pend d’Oreille and Kootenai Indians, and the areas 

where the tribes traditionally gathered these plants have been progressively affected by habitat loss, 

noxious weed displacement of native plants, herbicide use, livestock grazing, and a variety of other impacts 

associated with use of National Forest. Tribal access to and use of traditional cultural areas has also been 

affected by development of private lands, resource extraction on National Forest, and increased recreational 

use in traditional areas.

Cumulative effects will continue and intensify by additional impacts such as increasing population and new 

technology resulting in new uses of National Forest. Where recreational damage to cultural sites was once 

limited to areas adjacent to heavily used trails, roads and campsites, the increase in modern motorized 

recreation has caused more site damage by motorized vehicles running over archaeological sites. 

Deliberate looting and vandalism of cultural resources in remote areas has also increased with improved 

access. 

Failure to reduce the accumulated fuels would increase the potential for severe wildfire, increasing the 

potential for adverse effects by fire to cultural resources throughout and beyond the Lower West Fork 

project area, particularly cambium-peeled trees, trails, structures, and combustible artifacts. Wildfire also 

exposes sites by removing the vegetative cover and by subsequent erosion, which increases the risk of site 

looting and vandalism. Noxious weed encroachment within the project area has the potential to damage 

Alternative 1
Affected Environment and Environmental Consequences - Heritage

Lower West Fork Project Final EIS 3.11-5

cultural and traditional tribal use sites through erosion and the displacement of culturally important plant 

species.

Reduction of accumulated fuels will have the long term beneficial effect of reducing the threat of wildfire 

damage to cultural resources in the Lower West Fork watershed. Cultural resources that would benefit 

most because they are particularly vulnerable to wildfire include cambium-peeled trees, trails, structures,

and combustible artifacts. Wildfire also increases the risk of looting and vandalism because the loss of 

vegetative cover and soil erosion exposes sites. Noxious weed encroachment within the project area has 

the potential to damage cultural and traditional tribal use sites through erosion and the displacement of 

culturally important plant species.

Alternative 2

Limiting fuel reduction activities might reduce our ability to protect cultural resources during wildfire as 

under Alternative 2 and described above. Because Alternative 3 involves less ground disturbance than 

Alternative 2, there would be less potential to damage cultural and traditional tribal use sites through 

erosion and the displacement of culturally important plant species. 

Alternative 3

3.11.6 CONSISTENCY WITH THE FOREST PLAN AND OTHER REGULATORY 

DIRECTION 

Federal laws that direct the Forest Service to identify, evaluate, and protect cultural resources also regulate 

heritage and tribal interests. All of the alternatives would comply with Federal laws. The proposed 

alternatives meet Forest Plan standards, which tier to these laws.

Compliance with the National Historic Preservation Act, Section 106, is fulfilled under the Programmatic 

Agreement between the USDA Forest Service Northern Region and the Montana State Historic 

Preservation Office. 
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

Lower West Fork Project Final EIS 3.12-1

3.12 RECREATION, ROADLESS AND WILDERNESS

3.12.1 SCOPE OF ANALYSIS & ANALYSIS METHODS

The direct and indirect effects of the Lower West Fork project on recreation resources are analyzed across 

the analysis area. The ID Team selected this area because project activities may affect recreation specialuse authorization holders and recreation access for all types of Forest visitors.

We analyze existing recreation opportunities and changes to those opportunities to disclose the existing 

condition and potential effects on recreation from the proposed management. We use the attributes of

wilderness (FSH 1909.12, Chap.70) to assess the existing condition and compare the potential effects of the 

Lower West Fork project on inventoried roadless areas, unroaded areas, and wilderness areas. A crosswalk

between wilderness attributes and roadless characteristics is presented in Table 3.12-1.

3.12.2 REGULATORY FRAMEWORK

A. National Environmental Policy Act 

The National Environmental Policy Act (NEPA) requires integrated use of the natural and social sciences 

in all planning and decision-making that affects the human environment. The human environment includes 

the natural and physical environment and the relationship of people to the environment (40 CFR 1508.14).

B. Bitterroot National Forest Plan Direction

The Bitterroot National Forest Plan (Forest Plan) describes recreation management goals and standards for 

each Management Area (MA). The Lower West Fork project area includes MAs 1, 2, 3a, 3c, 5, 6, 8a, 9. 

Recreation management standards for each MA are as follows: 

MA1 – Manage for recreation activities associated with roads and motorized equipment. The recreation 

opportunity spectrum setting is roaded natural (USDA Forest Service 1987, pg. III-3).

MA2 – Manage for recreation activities associated with roads and motorized equipment. Off-road 

vehicle use will be controlled during critical periods on susceptible ranges such as high-use winter 

range, spring range, and densely roaded fall range. The recreation opportunity spectrum setting is 

roaded natural (USDA Forest Service 1987, pg. III-9).

MA3a - Manage to provide recreation opportunities associated with main access roads and fishing 

streams. The recreation opportunity spectrum setting is roaded natural or semi-primitive motorized 

(USDA Forest Service 1987, pg. III-16).

MA3c - Manage for recreation access to the Selway Bitterroot Wilderness. The recreation opportunity 

spectrum setting is roaded natural (USDA Forest Service 1987, p. III-30).

MA5 – Manage for recreation activities associated with roadless areas, including hiking, hunting, 

fishing, camping, motorbiking, and snowmobiling. The recreation opportunity spectrum setting is semiprimitive motorized and nonmotorized (USDA Forest Service 1987, pg. III-37).

MA6 – Maintain existing primitive and semi-primitive settings (USDA Forest Service 1987, pg. III-41).

MA8a - Manage for ROS setting and recreation activities associated with adjacent management areas 

(USDA Forest Service 1987, pg. III-58.).

MA9 – Discourage use in RNAs except along existing roads and trails (USDA Forest Service 1987, pg.

III-66).

There are no Forest-wide or Management Area standards specific to unroaded areas. 
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

3.12-2 Lower West Fork Project Final EIS 

C. Recreation Opportunity Spectrum (ROS)

The Forest Service uses the Recreation Opportunity Spectrum (ROS) to classify the variety of recreation 

opportunities available on National Forest. It describes recreation opportunities on a scale from “Urban” to 

“Primitive” (USDA Forest Service 1986). One can infer the types of recreation experiences they can 

expect by using the ROS. 

There is great disparity in opinions about the effects on a person’s recreational experience when they 

encounter others on the trail. Some people using non-motorized modes of travel become upset when they 

encounter or hear motorized equipment. The reverse situation is not true as frequently. Often the situation 

is defined as ‘user conflict’, but there generally is not a physical or safety conflict associated with one party 

encountering another party on the trail The situation is more accurately defined as a failure to fully meet 

the social expectation of the visitor not using a motorized vehicle for transport. 

D. Travel Management Direction

The Bitterroot National Forest Visitor Map (2005) displays motorized travel management restrictions, 

established under current Federal laws and regulations on National Forest. The Forest Service and Bureau 

of Land Management issued a decision in January 2001 to limit or restrict motorized wheeled cross-country 

travel on lands administered by the two agencies (USDI and USDA 2001). The decision restricts yearlong, 

wheeled motorized cross-country travel, where it was not already restricted. The Bitterroot National Forest

(Bitterroot NF) completed a Forest Plan Amendment and Special Order to implement this decision, and 

placed signs across the Forest by July 1, 2001. 

The Bitterroot NF mapped many user-created motorized trails but did not complete a total inventory. Since 

2002, the Forest has employed an off-highway vehicle (OHV) Ranger, numerous Forest Protection 

Officers, and two Law Enforcement Officers to enforce current travel management orders. Although there 

is not complete assurance of compliance to this order, the Bitterroot NF has successfully monitored and 

restricted illegal OHV use (USDA Forest Service 2004c, 2005, 2006 and 2007a, Item 28). When adverse 

environmental effects are occurring from OHV use, local managers have the ability to immediately close 

the road, trail, or area and repair the damage. 

In 2005, the USDA published the final travel management rule that regulates OHV use on National Forest. 

This “Final Travel Management Rule; Designated Routes and Areas for Motor Vehicles” changed the legal 

authority for regulating off-route travel. The decision mandates that all National Forests complete a travel 

management review for summer motorized road and trail uses, identify the appropriate class of vehicles for 

use on specific roads and trails, and specifically designate which routes are open to motor vehicles. 

Implementation of this rule is accomplished once a Forest has completed travel management revision 

through a public process, and published a Motor Vehicle Use Map (36 CFR 212.56).

Until designations for the Bitterroot NF are complete and a Motor Vehicle Use Map (MVUM) is published, 

existing travel management policies, restrictions, and orders remain in effect. Motorized vehicle changes in 

this proposal are implemented under 36 CFR 261 regulations and Special Orders until a MVUM is 

published. The Bitterroot NF initiated Travel Planning in 2007. They expect to publish a MVUM in 2010

(PF-REC-002). 

Montana State Code 61-9-418 regulates noise on public lands in Montana. This law states that all 

motorcycle or quadricycles operated on streets and highways in the state shall be equipped with noise 

suppression devices at all times. Forest roads and trails are considered public ways under the law, and are 

covered by this requirement. The Forest Service also has the authority under 36 CFR 261.15(d) to enforce 

noise standards set by other federal agencies and by the state. 
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

Lower West Fork Project Final EIS 3.12-3

3.12.3 AFFECTED ENVIRONMENT

Recreational uses of the Lower West Fork analysis area consists mostly of dispersed uses such as hiking, 

backpacking, firewood gathering, hunting, viewing scenery, mountain bike riding, picnicking, and all 

terrain vehicle (ATV) and snowmobile riding. There are six National Forest system trails within the 

analysis area and one developed recreation site. People who recreate in the analysis area are mostly local 

residents and residents of Ravalli County. 

Summer recreational use is generally low across the analysis area except at points of interest or trail access 

points. For example, vehicles parked at the Baker Lake trailhead average six vehicles per day from June 

through August, and about 10-12 vehicles per day during a busy weekend. Most use is day-use with an 

occasional overnight visitor. Visitors used roads and trails to access the 2007 Rombo Mountain Fire area 

more often in the summer of 2008 looking for mushrooms. Generally, however, use is light and sporadic 

throughout the summer. 

Hunting use is also light but more concentrated during the fall hunting season on the Piquett Creek side of 

the analysis area. OHV use also tends to increase during the hunting season. 

The Bitterroot NF has complete data from round one of the National Visitor Use Monitoring and West Fork 

Ranger District information. This nationwide visitor use survey provides statistically sound information 

about who visits the National Forest and why (USDA Forest Service 2003c) and is one source of 

information used in the following sections. In general, however, most of the people that use the Bitterroot 

NF do so for hiking and walking, and most tend to be viewing the natural features of the landscape, or are 

relaxing, and viewing wildlife. A very small percentage (1%) use motorized equipment such as OHVs and 

snowmobiles. Although this data reflects the entire Bitterroot NF, we estimate that these same trends apply 

to this analysis area. 

A. Recreation and Trails

The Lower West Fork analysis area provides local dispersed recreation opportunities. Trapper Peak and 

Boulder Creek trails are the two main access points to the Selway Bitterroot Wilderness. Seasonally, 

Trapper Peak Trail #133 receives moderate foot traffic (between 0-4 people/day) and is adequate for the 

use it receives. Boulder Creek Trail #617 receives moderate use (between 2-14 people/day) primarily from 

foot traffic. Boulder Canyon offers spectacular scenery and beautiful waterfalls, as well as, good loop trail 

opportunities desired by the long distance hiker. Baker Lake Trail #234 is a short hiking trail accessing 

Baker, Middle, and Gem Lakes. The trail also accesses the Selway Bitterroot Wilderness above Baker 

Lake and provides access to Trapper Peak ridge. Many hikers use this ridge as an alternate route to 

Trapper Peak. The trail and lakes are very popular for both day and overnight use because of the high 

quality scenery, fishing in Baker and Middle Lakes, and the alternate route to Trapper Peak. The road and 

parking area for Baker Lake was improved in August of 2008. The Observation Point just below the 

trailhead was also improved to facilitate parking. 

Piquett Creek Trail #675 and Piquett Divide Trail # 676 are on the east side of the analysis area and Shook 

Mtn.-Medicine Point Trail #601 is along the eastern most boundary of the analysis area. Use of these trails 

is low, though hunters and outfitters use them more often during the fall hunting season.

Dispersed recreation use in the area includes big game and bird hunting, day use fishing, berry picking, 

firewood gathering, Christmas tree harvest, scenic driving, and riding horses or mountain bikes. A few of 

the trails in the area are open to single track motorized vehicles and get low to moderate use during the 

summer and fall seasons. Sam Billings Campground is the only campground in the analysis area. This 

facility receives consistent summer use, filling to capacity on most holiday weekends. Because this

campground is so close to the Boulder Creek trail, the trail receives consistent weekend use during the 

summer and fall. 
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

3.12-4 Lower West Fork Project Final EIS 

The Boulder Peak Fire Tower sits high on the ridge above Boulder Creek. It has recently been restored and 

will be available to the public as a rental cabin in the near future. This recreation site receives very light 

use, mainly by local residents who are aware of the tower. The area receives light use by outfitters and 

guides who have day use and overnight big game hunting authorizations.

The ROS classifications reflect the recreation opportunities during spring, summer, and fall. The Forest 

Plan (USDA Forest Service 1987) mapped ROS classes based on several criteria, one of which is type of 

travel (motorized/non-motorized). Other criteria such as distance from trails, topography, private property,

and vegetative screening were used to adjust ROS boundaries. The ROS class for this area ranges from 

Primitive to Roaded Natural. Seventy percent of the analysis area is classified as primitive or semiprimitive non-motorized, and the other 30 percent is “semi-primitive motorized” or “roaded natural.” 

Recreation Opportunity Spectrum

B. Wilderness, Inventoried Roadless, and Unroaded Areas

There are two roadless expanses adjoining the analysis area, the Selway- Bitterroot and the Allan 

Mountain. Selway Bitterroot expanse is on the west side of the analysis area and includes the Selway 

Bitterroot Wilderness (1,340,000 acres), the Selway Bitterroot Roadless Area (115,625 acres), and 

unroaded blocks A (1,727 acres) and B (936 acres) (Fig. 3.12-1). The Allan Mountain roadless expanse 

includes the Allan Mountain Roadless Area (104,069 acres) and unroaded blocks C (4,718 acres), D (1,151 

acres), E (268 acres), F (1,250 acres), and G (3,106 acres). It lies to the south and east of the analysis area. 

The Selway Bitterroot Wilderness is not within the analysis area and activities are not proposed within it. 

A prescribed fire would extend into the Selway Bitterroot Roadless area. The Forest Service does propose 

activities within the unroaded areas adjacent to the roadless areas. The unroaded areas do not have a 

special designation; the Forest Plan and Management Area designations guide management. These areas 

do not have roads identified on the roads inventory but roadbeds may have been previously constructed. 

The 1964 Wilderness Act considered attributes of natural integrity, apparent naturalness, opportunities for 

solitude, and opportunities for a primitive recreation experience to determine whether areas possessed 

wilderness qualities. Forest Service Handbook (FSH) 1909.12, 72.1 discusses the attributes of wilderness, 

and additional attributes considered when evaluating potential wilderness areas. A cross walk between 

wilderness attributes and roadless characteristics is presented in Table 3.12-1 These attributes are used to 

evaluate existing conditions and compare the effects on wilderness quality in the roadless expanse. 

Table 3.12-1: Wilderness Attributes and Roadless Characteristics

WILDERNESS ATTRIBUTES ROADLESS CHARACTERISTICS

Natural Integrity: The extent to which long-term 

ecological processes are intact and operating.

High quality or undisturbed soil, water, and air. 

Source of public drinking water. Diversity of plant 

and animal communities. Habitat for threatened, 

endangered, candidate, proposed, and sensitive 

species dependent on large areas. 

Apparent Naturalness: Environment looks natural to 

most people.

Natural appearing landscapes with high scenic 

quality.

Solitude and Primitive Recreation: Personal subjective 

value defined as the isolation from the sights, sounds, and 

presence of others and the developments of man.

Primitive, semi-primitive non-motorized, semiprimitive motorized ROS classes of dispersed 

Remoteness: Perceived condition of being secluded, recreation.

inaccessible, and out of the way.

Unique Features: Unique and/or special geological, 

biological, ecological, cultural, or scenic features.

Other locally identified unique characteristics. 

Traditional cultural properties and sacred sites. 

Manageability/boundaries: Ability to manage a 

roadless area to meet the minimum size criteria (5,000 

acres) for wilderness.

No criteria.
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

Lower West Fork Project Final EIS 3.12 - 5 Figure 3.12-1: Selway-Bitterroot and Allan Mountain Roadless Expanses and Alternative 2 Treatment Units in the Lower West Fork Analysis Area
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

Lower West Fork Project Final EIS 3.12 - 7

The 1987 Bitterroot Forest Plan Final Environmental Impact Statement (USDA Forest Service 1987, 

Volume II) describes the Selway Bitterroot and Allan Mountain roadless areas. It contains maps and a 

detailed description and wilderness capability evaluation of each area.

About 3,855 acres of the 115,625 acres Selway Bitterroot roadless area (about 3%) is located on the western 

edge of the analysis area. The Selway Bitterroot roadless area extends along the east edge of the Selway 

Bitterroot Wilderness from just north of Baker Lake down to Boulder Point Lookout. The roadless area is

within easy access of the Bitterroot Valley. Four trails pass through the roadless area and provide access to 

the adjoining wilderness; numerous other trails access the roadless areas from outside the analysis area. 

Approximately eight miles of the 75-mile long roadless area is within the analysis area. Impressive 

mountain peaks and spectacularly rugged canyons form the scenic background for travelers and valley 

residents. These canyons are main access points to the Selway –Bitterroot Wilderness. 

Selway Bitterroot Roadless Area (01067)

Public interest to make this roadless area a wilderness is generally high, at least for a portion of the canyons. 

Classification of some canyon mouths would provide wilderness designation for entire drainages. 

Conversely, there is strong local demand to leave some of the canyons unclassified so there would be less 

potential for restrictions on recreation use, and allowance for developed recreation. Characteristics of this 

area that make it important from many perspectives include:

Ø Plant and animal communities are diverse because of the great variation in topography, with 

rocky canyon sidewalls, bedrock and rubble, open pine stands, and densely forested riparian 

areas. 

Ø Scenery and recreation opportunities are valuable amenities within the area, especially day 

hiking, fishing, big game hunting, rock climbing, and ski touring. 

Ø Water for irrigation is an important resource originating in or flowing through the area. 

The following section describes the resource values of this roadless area:

Natural Integrity

Natural integrity is the extent to which long-term ecological processes are intact and operating. The 

presence and magnitude of human-induced change to an area is the measure of project effects on natural 

integrity. Six canyon bottoms contain most of the pre-1985 impacts of human activity in the Selway 

Bitterroot roadless area. A dozer trail and mineral prospecting in the North Fork of Trapper Creek; several 

trail bridges and corduroy sections across boggy sections of trail; and isolated pockets of heavy recreation 

use along main trails are activities that effect natural integrity of the Selway Bitterroot roadless area in the 

analysis area. Baker Lake Trail #234, Trapper Peak Trail #133, Boulder Creek Trail #617, and Boulder 

Point Trail #247 create moderate effects on “natural integrity” in the analysis area. Non-native plants are 

encroaching into the area, and livestock use is evident in streams and open areas. 

Human activities outside of the analysis area on the Darby and Stevensville Ranger Districts affect the 

“natural integrity" of the Selway Bitterroot roadless area. These activities include:

Ø a dozer-constructed trail in Bass Creek

Ø a small irrigation dam and reservoir at High Lake

Ø two small abandoned irrigation dams at Kidney and Lower Camas Lake 

Ø an old jeep trail in the South of Lost Horse

Ø reservoir drawdown on Como, Upper Twin, and Fred Burr lakes

Ø irrigation diversion and ditch in the headwaters of Bear Creek

Ø a cabin on Larry Creek 

Impacts of all these activities in the roadless area affect less than 500 acres, including reservoir drawdown 

areas. Approximately 2,100 acres of timber were harvested using selection cuts and 90 acres were clearcut 
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness 

3.12 - 8 Lower West Fork Project Final EIS 

in the Selway Bitterroot Roadless Area from 1985 through 1993. Of the 2,100 acres, 120 acres were 

sanitation harvest in the Lower West Fork analysis area. 

Apparent Naturalness

Apparent naturalness means that the environment looks natural to most people using the area. It measures

visitor perceptions of human impacts on the area. Impacts are widely dispersed but evident to most visitors 

when onsite. However, because of the type of human related disturbances, the area has a high rating for 

natural appearance. Evidence of human activities near the adjacent roadless areas limits this area’s apparent 

naturalness, though at the site level, much of this area appears quite natural to the visitor. 

Use of old timber sale roads as OHV trails and heavy use of some trails by motorcycles and OHVs affects 

the apparent naturalness of the trail systems. Wheel tracks evident at mud holes, creek crossings, and steep 

grades degrade the apparent naturalness of the area. While most of the degraded areas are outside of the 

roadless area boundary, they still affect the apparent naturalness of the general setting. 

Remoteness

Remoteness is a perceived condition of being secluded, inaccessible, and out of the way. The physical 

factors that can create “remote” settings include topography, vegetative screening, distance from human 

impacts such as roads and logging operations (sight and sound). 

Civilization appears to be nearby when looking to the West Fork and Bitterroot Valleys from various view 

points within the roadless area. Vegetative and topographic screens enhance the user’s sense of remoteness 

in some areas. 

Opportunity for Solitude

Solitude is a personal, subjective value defined as isolation from the sights, sounds and presence of others, 

and human developments. Common indicators of solitude are numbers of individuals or parties one may 

expect to encounter in an area during a day, or the number of parties camped within sight and sound of other 

visitors. 

Human activity is moderate in this portion of the roadless area. The trails get moderate use throughout the 

year and some dead end in the canyons. Much of the terrain in the canyons and ridges in this area are rocky 

and steep. Opportunities for solitude are high, especially when one is away from the trails and areas where 

sights and sounds from the valley floor are evident. Knowing that over a million acres of wilderness lie to 

the west and observing the precipitous, glacially carved terrain enhances the feeling of solitude. 

Special Features and Special Places

Special features are those unique geological, biological, ecological, cultural, or scenic features that may be 

located in the area. In this part of the roadless area, there is a pleasant transition from densely forested 

stands of subalpine fir and lodgepole pine to the rocky, alpine timberline area. There are pockets of large 

ponderosa and Douglas-fir along the south-facing slopes. This rugged and scenic landscape has changed 

little since the ice age. The past activity that has had the most impact on the landscape is the suppression of 

natural fires. This habitat gives one a feeling of serenity and spaciousness. Mountain goats are sometimes 

visible on the rock slopes above Baker and Trapper drainages. Elk and deer summer on the more gentle 

sites. Falcons exist in all of these canyons. Magnificent views of past glaciation exist throughout this area. 

Big game hunting, fishing, and hiking the trail system to the many lakes in the Trapper, Baker, and Boulder 

Creek drainages makes up most of the human use in this area.

Manageability (Boundaries)

This element relates to the ability of the Forest Service to manage the area to meet size criteria and the 

elements discussed above. Changes in the shape of an area influence how it can be managed. The locations 

of projects proposed outside the area also need to be considered. Boundary management effects relate to 

such factors as the need to provide access to the area and to match boundaries to terrain features that can be 
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

Lower West Fork Project Final EIS 3.12 - 9

easily located. Manageability or boundaries was not a wilderness quality factor rated in RARE II, but is a 

factor considered since the mid-1990s to evaluate effects on roadless areas (FSH 1909.12 72.1(5)). 

The Selway Bitterroot roadless area abuts the Selway Bitterroot Wilderness on the west. The eastern 

boundary traverses mid-slope above roads and timber harvest units. The Selway Bitterroot roadless area 

contains good topographic features that facilitate identification of the Wilderness boundary (USDA Forest 

Service App. C 1987).

Unroaded Blocks A and B increase the size of the unroaded expanse by 1,727 and 936 acres, respectively. 

They essentially fill the gap between National Forest system roads and the Selway Bitterroot Roadless area. 

Block ‘A’ has a more or less rectangle shape located between Pierce Creek and Lavene Creek. It includes 

the lower, east-facing flanks of Trapper Peak. Block ‘B’ extends between the head of Troy Creek to about 

1⁄2 mile beyond Wheeler Creek. It is a narrow corridor between the road system and roadless area. 

Selway Bitterroot Unroaded Blocks

Parts of the unroaded blocks have been harvested previously (Fig. 3.12-2) and skid trails and roads remain 

from the past activities. 

Natural Integrity

Fire suppression currently alters the natural integrity of the unroaded lands. Fire is a natural condition on 

the landscape and was typically of high frequency and low severity, which maintained open ponderosa pine 

stands. The ponderosa pine, lodgepole pine, and Douglas-fir stands have higher tree stocking and fewer 

open grasslands than might be expected. Non-native, invasive plants are present in the area. These 

conditions create the potential for more severe fires. 

Apparent Naturalness

The unroaded blocks retain their apparent naturalness though timber harvest occurred in the 1980s. The 

harvest treatments were largely intermediate cuts that have left most of the forest overstory intact. 

However, a visitor may notice cut stumps and overgrown skid trails and roadbeds. More area was harvested 

in Block A than Block B. Roads adjacent to the blocks compromise the apparent naturalness because of 

their existence and the proximity to the sights and sounds of the human uses occurring on them. 

Remoteness

The presence of man is clearly recognizable in Block A and Block B. The proximity of roads and 

management activities on adjacent Forest and private lands diminish the perception of remoteness and 

seclusion. 

Opportunity for Solitude

Block A provides some opportunity for solitude as one moves deeper towards the roadless and wilderness 

areas. Ridges and slope breaks higher on the slopes obscure the view and sounds from the West Fork River 

valley floor. However, the lower flanks of the Trapper Peak face provide direct views to the sights and 

sounds of traffic and management on adjoining Forest and private lands in the West Fork River corridor. 

No topographic features in Block B obscure the sights and sounds of surrounding roads and on-going 

management. 

Special Features and Special Places

There are no special features in Block A. Boulder Canyon is a special feature in Block B and is designated 

as a Research Natural Area. 

Manageability (Boundaries)

Blocks A, and B adjoin the larger Selway Bitterroot Wilderness and Roadless areas and as such have the 

potential to be managed as Wilderness. 
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness 

3.12 - 10 Lower West Fork Project Final EIS 

Allan Mountain roadless area is located on the eastern edge of the analysis area, just north of Shook 

Mountain south to Piquett Lake. The analysis area overlaps approximately 9,494 acres or about 9% of the 

104,069 acres roadless area. About two-thirds of this roadless area is in Montana and the other third is in 

Idaho. The roadless area extends 28 miles, north to south, and is 13 miles wide, east to west. 

Allan Mountain Roadless Area (01946)

U. S. Highway 93 (Hwy 93) parallels the east side of the Allan Mountain roadless area and with the West 

Fork Road is the primary access to the roadless area. Several National Forest roads connect Hwy 93 and 

West Fork Road to 30 trailheads and about 150 miles of trail that provide access into the roadless area

interior. Four mining roads, totaling 17 miles, encroach into the area.

Elevations range from about 4,800 feet to 9,154 feet at Allan Mountain in Idaho. Topography is steep and 

generally rocky with shallow, sandy-loam soils. Drainage bottoms are narrow with steepened slopes rising 

to relatively narrow ridges. Forest covers most of the area except for peaks in the Allan and Piquett 

Mountain areas and at spots along the Montana – Idaho border. Streams are small, cold, fast flowing with 

gravelly rocky bottoms and support native fisheries. Current uses in the area are grazing, mineral 

exploration, and a variety of recreation activities. 

Natural Integrity

Mining, range management, and fire control activities are the primary impacts in the area. Most of the 

mining and range impacts are located on the Montana side. Mining activity includes dozer trails and 

prospect holes in the Overwhich Falls areas. Stub roads and pads or core drilling have been reclaimed to 

approximate natural contours. Mining access road corridors in Hughes and Mine Creeks, and Indian and 

McConn Creeks are outside the roadless area and the analysis area but are visible on an otherwise natural 

appearing landscape. 

On the Montana side, fences, stock water tanks, and a cabin in Warm Springs Creek are evidence of range 

activities. Helispots, cut along ridgetops, are the most evident fire control impacts. 

Man-caused impacts occur on less than 1% of the roadless area, most of which are near Overwhich Falls,

which is outside of the project area. These impacts are evident to users when onsite. Overall, the area is 

natural appearing. 

Apparent Naturalness

Impacts are widely dispersed but evident to most visitors when onsite. However, because of the type of 

human related disturbances, the area has a high rating for natural appearance. Evidence of human activities 

located near the undeveloped adjacent lands in the project area limits this area’s apparent naturalness, 

although at the site level, much of this area may appear quite natural to the visitor. 

Opportunity for Solitude

The size of the core area and topography offer excellent opportunities for solitude. This opportunity 

decreases in the southern portion of the roadless area along the state border due to its long, narrow 

configuration, and the greater opportunity to view man’s activities because of mid-slope boundaries.

Special Features and Special Places

Sub-alpine larch stands on Allan Mountain represent the southern limit of this tree species.

Overwhich Falls, while carrying a relatively small volume of water, is spectacular. The geologic processes, 

which led to Overwhich Creek cutting back through erosive materials and capturing the upper reaches of 

Fault creek, are impressive. 

High scenic values exist in the area around Allan and Piquett Mountains. Important cultural resources 

include a portion of historic southern Nez Perce Indian Trail and remnants of Forest Service, miner, and 

trapper cabins scattered through the area.
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

Lower West Fork Project Final EIS 3.12 - 11

Manageability (Boundaries)

The boundary of the Allan Mountain roadless area creates a large internal area around Allan Mountain with 

a broad peninsula encapsulating Shook Mountain, Rocky Knob, Medicine Point, and Rombo Mountain at 

the middle elevations. Most of the boundary is not on readily identifiable topographic features, but is 

defined by the upper limits of development in individual drainages (USDA Forest Service App. C 1987). 

The core area with the highest wilderness values encompasses the upper reaches of Warm Springs, Slate, 

and Overwhich Creeks. These areas are not part of the Lower West Fork analysis area. 

Blocks C, D, E, and F are directly adjacent to the Allan Mountain Roadless Area. Block G does not directly 

connect to the Allan Mountain roadless area but would connect through block F. Therefore, blocks F and G 

are analyzed as one block and referred to as block G since treatment is proposed in that portion of the block. 

No treatments are proposed in block D, except storing or decommissioning NFSR 13434, which lies 

between two lobes of it. Storing or decommissioning this road would enhance the roadless area attributes of 

this block. Block D is not analyzed further. 

Allan Mountain Unroaded Blocks

The area of Blocks F and G combined is about 5,150 acres, surrounded on the west, north, and east by 

private land. The southeast portion connects to the Allan Mountain Roadless Area and due south is actively 

managed National Forest. The area includes a trail from the Trapper Creek Job Corps that connects to the 

Shook Mountain trail. The west side of the block has a full view of the West Fork River Corridor and the 

east side has an open view to Highway 93 (HWY 93).

Block C is approximately 4,718 acres on either side of a north-south trending ridge. It forms an 

approximately 2-mile-by-2-mile peninsula north of the Allan Mountain Roadless Area and approximately 

1.5 to 2 miles east of the Shook Mountain peninsula of the Allan Mountain Roadless Area. The east side of 

the ridge is open because it burned in the fires of 2000. The gap between the roads and the west side of the 

ridge is narrower, less than one mile but more densely forested. Smaller areas burned in 2000 and a road 

traverses the area from NFSR 5719 to the trail on the ridge. Previous treatments numerous roads directly 

adjacent to the north border of Block C detract from the roadless attributes on the northern edge. 

Block E is 268 acres adjoining the west side of the Shook Mountain peninsula of the Allan Mountain 

Roadless Area. Block E includes three north facing spur ridges into East Piquett Creek. The southern part 

of the block encompasses a narrow saddle and knob. 

Natural Integrity

Fires in 2000 and 2007 burned large parts of blocks C, E, and G. Ponderosa pine stands in the burned areas 

are open but those that did not burn, the Applebury-Pine Creek area, have higher tree stocking and fewer 

open grasslands than might be expected. Non-native, invasive plants are present in the area. 

Apparent Naturalness

The unroaded blocks retain their apparent naturalness though timber harvest occurred in the 1970s through

1990s. The southern part of Block E had clearcut, shelterwood, and intermediate harvests in the 1980s. 

Also, in the 1980s, the western and eastern portions of block C had shelterwood and intermediate harvests. 

In the 1990s, the northwest edge of Block C and the southern part of Block G had intermediate harvests. 

Thus, a visitor may notice cut stumps; skid trails and roadbeds. The skid trails and roadbeds may be more 

apparent since the fires burned through the areas. 

Open areas in Block E would have signs of past livestock use though the allotment is inactive. No livestock 

allotments occur in the other unroaded blocks.

Trails 601, 675, and 676 are open to motorcycles, hiking and stock. These trails pass through blocks C and 

G. Though use is light, the presence of the trail detracts from the apparent naturalness. 
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness 

3.12 - 12 Lower West Fork Project Final EIS 

Remoteness

Block G has steep, west and north facing slopes on the east side of the West Fork River, within less than a 

quarter mile of West Fork Road, and steep east facing slopes with views of the upper Bitterroot Valley and 

the HWY 93 corridor. The fires in 2000 burned the slopes in Block G and created large openings. The west 

side of Block ’C’ also has steep, northwest-facing slopes on the east side of West Fork River. Human 

activity along the West Fork Road, at Trapper Creek Job Corps, and on private lands is visible and audible 

from most of these areas. Block E has a network of roads on all sides including a remnant road from the 

previous clearcut.

Opportunity for Solitude

The opportunity for solitude is low in Blocks G and E, and on the periphery of Block C. The slopes in 

Block G and in the Applebury-Pine area of Block C are in full view and hearing distance of the sights and 

sounds of the West Fork River corridor. The east side of Block G has a full view of the Hwy 93 corridor 

though distance from the corridor may muffle the sounds of traffic. The center of Block G would provide 

the highest opportunity for solitude as the surrounding ridges would block the sights and sounds of man. 

The east side of Block C has better opportunities for solitude though the ridges face Piquett Creek. From 

about 1⁄2 mile below Britts Creek into the Castle Creek drainage, the roads are closed year-round to full size 

vehicles and closed during hunting season (10/15-12/01) to off-highway vehicles. Trails open to 

motorcycles, hiking, and stock (Trails 675 and 676) run along Piquett Creek and Piquett Divide. The sights 

and sounds of motor vehicles and mechanized use can be seen and heard in some areas but landforms 

obstruct the sights and sounds in other areas of the block. The northern edge of Block C is adjacent to roads 

open all year to full-size vehicles or off highway vehicles. 

Special Features and Special Places

There are no known special features in blocks C, E, or G.

Manageability (Boundaries)

Blocks C, E, and G adjoin the larger Allan Mountain Roadless areas and as such have the potential to be 

managed as Wilderness. 

3.12.4 ENVIRONMENTAL CONSEQUENCES 

A. Direct and Indirect Effects

Recreation and Trails 

Effects Common to All Alternatives

Enforcement of motorized use restrictions, and other regulations would continue. This area would continue 

to patrolled and monitored by our OHV Ranger (USDA Forest Service 2000f, 2001, 2002b, 2003b, 2004a, 

2005a, 2006a, 2007a, and 2008a, item 28). Existing road and regulatory signs, including travel 

management, would be posted and replaced as possible. 

User-created routes existing prior to 2001 would continue to be open to motorized use until the Bitterroot 

NF completes travel planning (scheduled for 2010). The cutting or clearing of a trail is illegal. However,

once a trail is in place, it is difficult to cite anyone riding it because it would appear to be used and legal. 

This would continue until the new travel rule is implemented. 

The continuation of ongoing management activities is common to all alternatives, including patrolling by an 

OHV Ranger during the summer months, educational signing at bulletin boards and trailheads, and 

education in schools and with user groups. 

Summer safety on motorized roads and trails, while not a major problem to date on the Bitterroot NF, could 

become a larger problem in the future due to increasing numbers of visitors (pers. comm. Jackie Clark, LEO 

administrative assistant 2007). With more visitors using the forest, interactions between motorized users 

and “quiet users” (bicycles, stock, and hikers) would increase.
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

Lower West Fork Project Final EIS 3.12 - 13

No alternative would change recreation opportunities in the analysis area. The trend of low and intermittent 

use is expected to continue for the various recreational activities. Use at developed sites is expected to 

increase because of the growing population in the valley and surrounding communities. 

In the event of wildfire, the intensity and severity of the fire is potentially greater in Alternative 1, than in 

Alternatives 2 and 3 because no fuel reduction would occur under Alternative 1. Wildfire could cause 

temporary forest road closures and jeopardize public health and safety. 

Alternative 1

Alternative 1, the No Action alternative, would not change or affect the existing recreational opportunities, 

existing travel access, nor the unroaded lands described in this section, since no new management activities 

would occur.

Recreation and Trails

Alternatives 2 and 3

In both action alternatives there may be an increase in OHV cross-country travel because there would be 

less vegetation in the stands. One method of cross-country travel would be to drive on skid trails. This

potential attraction would be low because skid trails visible from a road would be covered with slash from 

the timber harvest. Slash on skid trails effectively closes the trail to motorized use and is a required 

mitigation measure in all action alternatives (Chapter 2, Table 2.5). Another method of cross-country travel 

would be to drive through the wider spaced stands. The potential of this occurrence could increase in both 

action alternatives in the short term (5-15 years) because maintenance burning would keep stands more 

open. However, the potential for this activity is low because there are no areas of concentrated OHV use in 

the Lower West Fork analysis area, most units are too steep and do not provide the destination or viewing 

opportunities most OHV users’ desire. The potential to drive cross-country, though low, would be greatest 

under Alternative 2 because more area would be treated. The harvest areas would be high priority for OHV 

Ranger and Forest Protection Officer patrols to deter cross-country travel and address problems as soon as 

possible. 

Prescribed burning is proposed in Unit 70 under both Alternatives 2 and 3. This unit falls within the 

Boulder RNA and its southern boundary is on the Boulder Creek Trail #617. Ignition would occur within 

approximately 66 feet (a chain length) of the trail with a hose-lay adjacent to the trail to prevent burning and 

degradation of the trail. Mop-up would occur within 1-2 chains from the trail following ignition. Wooden 

waterbars and signs will be protected and replaced if burned.

In both action alternatives dispersed recreation activities such as fishing, hiking, camping, mountain lion 

hunting, motorized use, snowmobiling, and firewood gathering may be displaced to other areas during

harvest or burning operations. Noise from equipment working on the project and smoke from prescribed 

fires would be noticeable to adjacent landowners and recreational users while the work was occurring. 

Tree stumps and harvest slash would be apparent to Forest users traveling through treatment areas until 

vegetation was established and slash burned. Prescribed fire would kill smaller trees and some of the larger 

ones. These effects would be temporary and the flush of new plant growth would modify the burned 

landscape within several years. 

Harvest and fuel reduction activities in all action alternatives have the potential to affect user safety. 

Logging equipment may be present on roads and block a portion of the roadway. There would be an 

increase in logging traffic on forest roads, including log trucks. 

The analysis area is open to motorized travel on some of the existing road system in the spring, summer, and 

winter. Snowmobile use, cross-country and on roads, is restricted to the lower elevations to protect elk 

security. Use is light-to-moderate on roads open to snowmobiles. It will likely remain light though forest 

canopy openings may facilitate access because of unpredictable snow conditions on these low elevation sites

and the treatment units do not access destination or scenic points of interest.
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness 

3.12 - 14 Lower West Fork Project Final EIS 

Recreation Opportunity 

Following the implementation of the proposed road management actions, there would be over 50 miles of 

roads in the analysis area open yearlong to all motorized users.

The recreation opportunity spectrum, or experiences that the public could expect in the analysis area, would 

remain at approximately 36 percent non-motorized (primitive or semi primitive-nonmotorized), and 64

percent motorized (semi-primitive motorized or roaded natural). 

While there would be changes in motorized vehicle use on 14.4 miles of road, the recreation opportunity for 

non-motorized or quiet users would not necessarily increase as you would still hear or see motorized use 

from adjacent routes. 

Proposed temporary road construction would not increase the motorized recreation opportunity because the 

roads would be recontoured following use. 

Access Travel Management 

Travel management as a recreation opportunity was not addressed in any action alternative. However, due 

to resource concerns, several road management changes are proposed to improve overall soil, watershed,

and fisheries conditions by reducing road impacts and restoring soils on terraced lands in the area. Please 

refer to the Watershed (Section 3.6), Soils (Section 3.5), and Fisheries (Section 3.7) sections for a more 

complete description and discussions about why, how, and when these access management changes may 

occur.

Selway Bitterroot Roadless Area Expanse

For most of the roadless expanse, the project area is out of sight and inaudible and would have little impact 

on remoteness. The proposed activities would not markedly diminish the natural appearing nature of the 

area. The components of the roadless area expanse – Wilderness, Inventoried Roadless Area, and unroaded 

areas, effects vary based on their proximity to the proposed activities. 

Wilderness 

There would be no direct effects on Wilderness characteristics since no activities are proposed within 

Wilderness. Indirect effects may include sights and sounds of commercial and small tree thinning activities 

on non-wilderness lands. The sights and sounds of the work crews and their equipment might affect 

solitude and primitive recreation within wilderness in some places, although proposed activities are 

downstream and miles from wilderness boundaries. The distance from proposed activities to the wilderness 

and intervening landforms would mitigate noise and smoke from proposed activities. Noise would be at 

levels below ambient wilderness sounds.

Inventoried Roadless Area

Prescribed burning in unit 70 is the only management activities proposed within the roadless area in both 

Alternatives 2 and 3. Approximately 72 acres of Unit 70 overlap the Selway Bitterroot roadless area. This 

activity would not affect natural integrity because fire is a natural condition on the landscape and influenced 

the development of the forest community. Effects on apparent naturalness would be minimal and of short 

duration during implementation of the prescribed fire. 

The attributes most at risk in the inventoried roadless area are those associated with remoteness and solitude 

during project implementation. The sights and sounds of logging adjacent to the roadless areas would 

diminish each of these attributes for the period of logging and after logging until all the proposed projects 

are complete and ground cover has re-grown. Visitors in the roadless area may view and experience sights 

and sounds from the project area.

The project would not be diminish water quality in the roadless expanse because water does not flow into 

the inventoried roadless area from the project area. Air quality effects are minor and described in Section 

3.4. Effects on wildlife and threatened and endangered species (TES) would be minimal (see Sections 3.8 

and 3.10). The project does not create new access into the roadless area or change the recreation experience. 
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

Lower West Fork Project Final EIS 3.12 - 15

Selway Bitterroot Unroaded Areas

In Block A, 149 acres are proposed for commercial thin and prescribed fire and 641 acres would be 

prescribed fire only (Table 3.12-2). Units 33, 61A, and slivers of units 32 and 60A would be treated using 

prescribed fire. The prescription would be a low intensity burn except the higher elevations of Units 32 and 

61A would have moderate intensity burns. These treatments would not greatly affect the unroaded values 

because low and moderate intensity fires are typical of these ecosystems and influenced the development of 

these forest communities. Though the appearance of the vegetation would change, it would be within the 

parameters of natural integrity and apparent naturalness. Visitors would see charred duff and scorched 

underbrush and possibly lower branches of the overstory forest in the low intensity burns and patches of 

burned trees and areas of scorched ground in the moderate intensity burns. Fire scars are evident throughout 

the area. Fireline construction and the number of personnel on site to manage the fire would compromise 

the attributes of remoteness and solitude during the prescribed fire.

Table 3.12-2: Alternative Comparison of the Proposed Treatments in Unroaded Areas.

The upper half of Unit 34 and Unit 35 would affect the unroaded values most under both Alternatives 2 and 

3 (Fig. 3.12-1). Commercial thins are proposed in these areas and require the construction of approximately 

0.9 mile of temporary roads and TLM trails. The proposed skid trails, temporary roads, and TLM trails 

would be restored following their use (FEIS pg. 2-18). The roads and trails would detract from apparent 

naturalness during project implementation until such time that they are rehabilitated and ground cover is reestablished. Project implementation activities would reduce the attributes of remoteness and solitude by the 

presence of workers, vehicles, and the sounds of equipment. However, these attributes are already low 

because the units border roaded areas provide direct views to the sights and sounds of traffic and 

management on adjoining Forest and private lands in the West Fork River corridor.

In Block B, approximately 135 acres of commercial thin with prescribed fire and 54 acres of prescribed fire 

only. Unit 70 would have a low intensity prescribed burn, which would not affect the unroaded values 

because this type of fire is a natural feature of this ecosystem. The effects would be the same as described 

for Block A.

Preliminary sale layout indicates that only the ground-based portions of Unit 4 would be thinned, which

eliminates most of the unroaded portion in that unit. Commercial thin is also proposed for the unroaded 

portion of Unit 10. No roads are proposed in Unit 10 and the overstory would remain intact. Therefore, 

there would be no effects on natural integrity, apparent naturalness, remoteness, or solitude. The values of 

these attributes are currently low because of their proximity to roads, and the sights and sounds of man 

along the West Fork River corridor. Approximately 0.2 mile of temporary roads border the unroaded areas 

in Units 70, 7, and 4. The roads and trails would detract from apparent naturalness during project 

implementation until they are rehabilitated and ground cover is re-established. Project implementation 

activities would reduce the attributes of remoteness and solitude by the presence of workers, vehicles, and 

Type of 

Management/Treatment

Alternative 2 

A

Alternative 3 

B C D E G A B C D E G

Total Block Size 1,727 1,035 8,897 1,151 268 5,150 1,727 1,035 8,897 1,151 268 5,150

Block size in Lower West 

Fork analysis area (acres) 1,727 936 4,718 1,151 268 1,146 1,727 936 4,718 1,151 268 1,146

Non-Commercial Thin

(acres) 4 1 8 -- -- -- 4 1 8 -- --- --

Commercial Thin and 

Prescribed Fire (acres) 149 135 -- -- 21 3 149 135 -- -- 8 --

Prescribed Fire only (acres) 641 54 -- -- -- 193 641 54 -- -- -- --

Temporary Roads (mile) 0.9 0.2 -- -- 0.2 0.9 0.2 -- -- 0.2 --

Total management/treatment 

in unroaded areas (acres) 794 190 8 -- 21 196 794 190 8 -- 8 --
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness 

3.12 - 16 Lower West Fork Project Final EIS 

the sounds of equipment. Because the roads are on the periphery of block B, they do not detract from the 

current roadless area attributes. 

Roads proposed for decommissioning or storage in blocks A or B would not enhance the roadless attributes 

of either block because other roads directly adjacent to the blocks remain. 

Allan Mountain Roadless Area Expanse

For most of the roadless expanse, the project area is out of sight and inaudible and would have little impact 

on remoteness. The proposed activities would not markedly diminish the natural appearing nature of the 

area (Fig. 3.12-2). The components of the roadless area expanse –Inventoried Roadless Area, and unroaded 

areas, effects vary based on their proximity to the proposed activities. 

Inventoried Roadless Area

No management activities are proposed within the Allan Mountain Roadless area. Therefore, there are no 

direct effects on the roadless area attributes. 

Project implementation may indirectly affect the inventoried roadless area attributes associated with 

remoteness, and solitude. The sights and sounds of logging adjacent to the roadless areas would diminish 

each of these attributes for the period of logging and after logging until all the proposed projects are 

complete and ground cover has re-grown. Visitors in the roadless area may view and experience the sights 

and sounds from the project area. These effects would be limited to the west side of the Shook Mountain 

ridge portion of the Allan Mountain Roadless Area but would not affect roadless area attributes in the core 

of the Roadless Area. 

Project implementation would not diminish resources such as water and air quality, wildlife, and TES in the 

Allan Mountain Roadless Area (Sections 3.4, 3.6, 3.8, and 3.10). The project does not create new access 

into the roadless area or change the recreation experience. 

Allan Mountain Unroaded Areas

In Block G, there is a minor amount (3 acres) of commercial thin with underburn and 193 acres of 

prescribed fire in Units 64 and 71. These units would be low intensity prescribed burns and would not 

greatly affect the unroaded values. Low intensity fires are typical of these ecosystems and influenced the 

development of these forest communities. Though the appearance of the vegetation would change, it would 

be within the parameters of natural integrity and apparent naturalness. Visitors would see charred duff and 

scorched underbrush and possibly lower branches of the overstory forest in the low intensity burns. Fire 

scars are evident throughout the area. Fireline construction and the number of personnel on site to manage 

the fire under Alternative 2 would compromise the attributes of remoteness and solitude during the 

prescribed fires. Under Alternative 3, roadless attributes would not be affected in Block G because 

prescribed fire or other treatments are not proposed. 

In Block E, there are 21 acres of commercial thin with prescribed fire under Alternative 2 and eight acres 

under Alternative 3. There are no prescribed fire only treatments under either of these alternatives. Two 

tenths of a mile of temporary road would be needed to treat Unit 89 under both alternatives. The TLM trail 

on the border of Units 89 and 24 would detract from apparent naturalness during project implementation 

under both alternatives. The TLM trail would be obliterated and ground cover re-established within two 

years (FP II-23(6)). Therefore, it would not create more access into the area. The road density and terrace 

units adjacent to Units 89 and 24 detract from the sense of apparent naturalness, remoteness, and solitude. 

Project implementation activities would further reduce these attributes by the presence of workers, vehicles, 

and the sounds of equipment not only in these two units but in those on the periphery of the unroaded area. 

In Block C, there are eight acres of non-commercial thin in the northeast corner under both alternatives. 

The effects on roadless attributes would be minimal because numerous roads directly adjacent to Unit 98 

already compromise those attributes. The previous harvest detracted from the apparent naturalness of the 

area. There are no other activities proposed in Block C so the effect is limited to the northeastern corner. 
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

Lower West Fork Project Final EIS 3.12 - 17 Figure 3.12-2: Proximity of Roads, Past Management, and Alternative 2 Treatments Adjacent to the Selway-Bitterroot and Allan Mountain Roadless Expanses in the Lower West Fork Analysis Area
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness

Lower West Fork Project Final EIS 3.12 - 19

Noise from thinning and vehicles accessing the non-commercial thin units north of Block C would 

temporarily diminish attributes of solitude and remoteness. 

Road closures adjacent to the Allan Mountain Roadless Area or unroaded blocks would not improve 

roadless area attributes because numerous roads remain directly adjacent to the unroaded blocks. One road 

segment would be decommissioned in the Allan Mountain Roadless Area but the segment is so short 

relative to the roadless area the effect would be unnoticeable outside of the immediate vicinity. 

B. Cumulative Effects

A reasonably foreseeable future activity that will affect motorized use in the Lower West Fork Analysis 

Area is Travel Management Planning. When the MVUM is printed, there would be a shift from open unless 

posted closed to closed unless mapped open. Users would be provided with clear, well-defined motorized 

travel routes and clearly define areas where motorized use is not allowed. This will require fewer travel 

management signs in the field, which are difficult to maintain in some locations. 

Recreation and Trails 

Past activities and events that have influenced recreation use of this area include fires, timber salvage, and 

restoration work, road and trail maintenance (or lack thereof), the Off Highway Vehicle Final EIS 2001, 

Travel Management planning, current hunting regulations, Private land development, and increased 

residences adjacent to the National Forest. 

These events and activities have cumulatively created the existing setting in which a variety of recreation 

uses take place, generally on weekends and generally by users from the south Bitterroot Valley. 

The close proximity of growing communities, easy access, and outstanding views will continue to draw 

more and more users to this area. Private land development adjacent to the Forest boundary will likely 

continue, increasing the number of forest neighbors using the Lower West Fork area for recreation, and 

interacting with other Forest users. 

In summary, there are not substantial cumulative effects on recreation considering past, present, and 

reasonably foreseeable activities and projects in conjunction with the proposed actions associated with this 

project. 

The past, present, and reasonably foreseeable actions will have minimal cumulative effects on the 

wilderness and roadless attributes of the unroaded expanse in the project area. The areas with the highest 

wilderness and roadless attributes would remain unchanged in the long term (Fig. 3.12-2). 

Wilderness, Roadless Areas, and Unroaded Areas

Road construction and timber harvest have not directly affected wilderness attributes and have had minor 

effects on roadless attributes in the Selway Bitterroot and Allan Mountain roadless expanses as described in 

the existing condition and Forest Plan monitoring reports. 

Unroaded areas closest to the roaded areas are most affected by ongoing and proposed management 

activities. Unroaded areas closest to the roaded areas also have the lowest roadless and wilderness 

attributes.

Selway Bitterroot Roadless Expanse

The Selway Bitterroot roadless expanse consists of 1,340,000 acres of designated Wilderness 92%), 115,625 

acres of Inventoried Roadless Area (8%), and 2,663 acres of unroaded area in and adjacent to the Lower 

West Fork analysis area. Treatments proposed in the Lower West Fork project would affect 0.07% of the 

roadless expanse. Treatments would occur on the edge of the roadless expanse and their effects would be 

limited and of short duration. 

Under the 2004 Weed EIS, the Forest Service can treat weed infestations in specific locations in roadless 

areas. The 2009Selway Bitterroot Weeds EIS extended this management option into the Wilderness. Weed
Affected Environment & Environmental Consequences – Recreation, Roadless and Wilderness 

3.12 - 20 Lower West Fork Project Final EIS 

treatments benefit wilderness and roadless areas by eliminating weeds and potential sources of weed spread. 

Weed suppression actions in the project area would not have adverse cumulative effects on roadless 

attributes. Suppressing weeds would favor recovery and spread of desirable native plant species. 

Annual trail maintenance will be ongoing throughout the Selway Bitterroot roadless expanse. This work 

involves clearing the trail of fallen logs, cleaning waterbars, and brushing. During this time, workers may 

be visible in the roadless area. The activity will be temporary and restricted in area. The potential 

cumulative effect of this disturbance and the actions in Alternatives 2 and 3 on solitude would be restricted 

to a small area. 

Allan Mountain Roadless Expanse

The Allan Mountain roadless expanse consists of 104,069 acres of Inventoried Roadless Area (87%) and 

15,466 acres of unroaded lands (13%) in and adjacent to the analysis area. Proposed treatments would 

affect almost 0.2% of the unroaded expanse in Alternative 2 and 0.01% of the unroaded expanse in 

Alternative 3. Treatments would occur on the edge of the roadless expanse and the effects would be limited 

and of short duration. 

The Piquett Creek grazing allotment covering the unroaded portions of the project area is in vacant/reserved 

status and is used on an occasional “as needed” basis. 

Annual trail maintenance will be ongoing throughout the Allan Mountain roadless expanse. This work 

involves clearing the trail of fallen logs, cleaning waterbars, and brushing. During this time, workers may 

be visible in the roadless area. The activity will be temporary and restricted in area. The potential 

cumulative effect of this disturbance and the actions in Alternatives 2 and 3 on solitude would be restricted 

to a small area. 

In summary, there are not substantial cumulative effects on wilderness and roadless values considering past, 

present, and reasonably foreseeable future activities and projects in conjunction with the proposed actions 

associated with this project.

3.12.5 CONSISTENCY WITH FOREST PLAN, LAWS, AND REGULATIONS

All alternatives are consistent with Forest Plan directions and Interim directives regarding inventoried 

roadless areas and the Wilderness Act of 1964. No treatments are proposed in the Selway Bitterroot

Wilderness and prescribed fire is the only treatment that extends into the Selway Bitterroot Roadless Area. 

No treatments occur in the Allan Mountain Roadless Area.
Affected Environment & Environmental Consequences - Economics

Lower West Fork Project Final EIS 3.13 - 1 

3.13 ECONOMIC ANALYSIS

Several updates in the economic analysis were made between the draft and final EIS. Silvicultural updates 

were incorporated in the feasibility, efficiency, and employment and labor income analyses. 

Total harvest area dropped from 1,764 to 1,702 acres in Alternative 3, and non-sawlog material was 

reduced from 36 percent to 28 percent of harvested volume, which is the same ratio of sawlog to nonsawlog used in Alternative 2. In both Alternatives 2 and 3, mandatory hand piling, papering, and pile 

burning increased from 128 to 297 acres. The following optional activities changed in Alternative 2

Ø Prescribed burning/maintenance decreased from 1,704 to 1,680 acres 

Ø Hand piling, papering, and pile burning increased from 65 to 159 acres

Ø Three optional road maintenance sites shifted to two mandatory sites. 

In Alternative 3, the following optional activities changed: 

Ø Non-commercial thinning increased from 83 to 295 acres 

Ø Slashing decreased from 3,031 to 2,960 acres 

Ø Prescribed burning/maintenance decreased from 1,121 to 1,081 

Ø Hand piling, papering, and pile burning increase from 26 to 214 acres 

Ø Three optional road maintenance sites shifted to one mandatory site 

These changes resulted from additional field verification and refinement of the alternatives or from errors 

discovered on review of the draft environmental analysis.

Notably, expected revenue was adjusted by updating appraisals with the most recent information. Volume 

separated into sawlog and non-sawlog material, now includes a small product adjustment for non-sawlog 

material, which was applied to the predicted high bid for sawlog material. This new predicted high bid for 

each alternative was multiplied by sawlog volume and added to the sawlog volume multiplied by the base 

rates. There were also updates made to the project costs associated with design modifications. 

The net effect of these changes is a slight decrease in supplementary funding needed to implement the 

design criteria but little change was made in the amount of supplemental funding needed to accomplish all 

mandatory and optional work covered under this analysis. The lower revenue estimates and adjusted cost 

activities reduced the present net value for each alternative. The slight design changes in each alternative

caused the jobs and labor income estimates to increase slightly for Alternative 2 and decrease slightly for 

Alternative 3. These changes slightly increased the difference in the part- and full-time estimates between 

full implementation of Alternatives 2 and 3 from 48 to 49 part and full time jobs spread over the five- year 

project duration. 

3.13.1 SCOPE OF ANALYSIS AND ANALYSIS METHODS

The geographic scope of the economic and social analysis includes Missoula and Ravalli Counties. This is 

an appropriate scope of analysis because the project would occur in southern Ravalli County. Ravalli and

Missoula Counties make up the Bitterroot National Forest (Bitterroot NF) economic impact area (Montag 

and Stockmann 2006). The temporal scope of the analysis is four years, the duration of the proposed 

activities (2010 – 2014).

This analysis assesses potential economic impacts from proposed activities. Analysis methods are 

described in this section. The Purpose and Need for this project in Chapter 1, Section 1.2 of this document 

states, “The proposed Lower West Fork project would manage vegetation to reduce fuel loads and crown 

fire hazard in the wildland urban interface, improve forest health and resilience to disturbances, and 

maintain or increase shade intolerant species such as ponderosa pine and aspen. Roads would be evaluated

for opportunities to reduce sedimentation and restore aquatic passage. Terraced lands would be evaluated 

for opportunities to restore soils.” 
Affected Environment & Environmental Consequences - Economics

3.13-2 Lower West Fork Project Final EIS 

The economic measures for the analysis methods are displayed in Table 3.13-1. 

Table 3.13- 1: Economic Measures of Success and Analysis Methods

A. Project Feasibility 

Project feasibility relies on the Region 1 Transaction Evidence Appraisal (TEA) System to determine if a 

project is feasible – will it sell, given current market conditions. The TEA uses regression analysis of 

recently sold timber sales to predict bid prices. We used the most recent appraisal model for the area of 

interest to estimate the stumpage value (expected high bid resulting from the timber sale auction) for the 

timber project. The estimated stumpage value for each alternative was compared to the base rates. Base 

rates are essential revenues needed to cover stand regeneration and the minimum return to the federal 

treasury) of that alternative. The project would be feasible when the estimated stumpage value exceeds the 

base rates. If the feasibility analysis indicates that the project is not feasible (estimated stumpage value is 

less than the base rates), the project may be modified. The infeasibility of a project indicates an increased 

risk that the project may not attract bids and may not be implemented (36 CFR 223.61 and FSM 2430.2). 

B. Financial Efficiency 

Financial efficiency provides information relevant to the future financial position of the program if the 

project is implemented. Financial efficiency considers anticipated costs and revenues that are part of Forest 

Service monetary transactions. Present net value (PNV) is used as an indicator of financial efficiency and 

is one tool used in conjunction with many other factors in the decision-making process. The PNV 

combines benefits and costs that occur at different times and discounts them into an amount that is 

equivalent to all economic activity in a single year. A positive PNV indicates that the alternative is 

financially efficient. Financial efficiency analysis is not intended to be a comprehensive analysis that 

incorporates monetary expressions of all known market and non-market benefits and costs. Many of the 

values associated with natural resource management are non-market values that are not part of the financial 

efficiency analysis but are considered in the decision framework. These non-market benefits and costs 

associated with the project are discussed throughout the EIS. 

C. Economic Impacts (Jobs and Labor Income) 

Economic impacts are used to evaluate potential direct, indirect, and cumulative effects on the economy. 

The Forest Service uses IMPLAN Pro software (MIG 2003), an "input-output" analysis method, to estimate 

employment and income impacts. Input-output analysis (Miernyk 1965) is a way to examine relationships 

within an economy both between businesses and between businesses and final consumers. It captures all 

monetary market transactions for consumption in a given time period. This economic impact analysis 

examines the effect of a change in one or several economic activities on an entire economy when all else is 

constant. IMPLAN translates changes in final demand for goods and services into changes in economic 

effects, such as labor income and employment of the affected area’s economy. The IMPLAN modeling 

system allows one to build regional economic models of one or more counties for a particular year. The 

regional model for this analysis used 2004 IMPLAN data for Missoula and Ravalli Counties of Montana, 

the economic impact area of the Bitterroot NF. 

The economic impacts are measured by estimating the direct employment (full- and part-time jobs) and 

labor income generated by the 1) processing of the timber volume from the project, and 2) dollars resulting 

from any restoration activities of the project into the local economy affected by the proposed treatments. 

The direct employment and labor income benefit employees and their families and therefore directly affect 

the local economy. Additional indirect and induced multiplier effects (ripple effects) are generated by the 

Measures of Success for Economics Analysis Method

Available Revenue Region 1 Transaction Evidence Timber Appraisal

Present Net Value Quicksilver Financial Efficiency Analysis 

Employment & Labor Income IMPLAN Economic Impact Analysis
Affected Environment & Environmental Consequences - Economics

Lower West Fork Project Final EIS 3.13 - 3 

direct activities. Together the direct and multiplier effects comprise the total economic impacts to the local 

economy. The University of Montana’s Bureau of Business and Economic Research provided the data 

used to estimate the direct effects of timber harvest and processing. The multiplier effects tied to the timber 

harvest and processing, and restoration activities were estimated using IMPLAN. Potential limitations of 

these estimates are the time lag in IMPLAN data and the data intensive nature of the input-output model. 

D. Environmental Justice 

Environmental justice effects report what effects might occur to ethnic or disadvantaged peoples. Of 

particular concern is whether job or income discrimination might occur to ethnic or disadvantaged citizens 

in the area during or resulting from the proposed project. 

3.13.2 REGULATORY FRAMEWORK

The Bitterroot National Forest Plan (Forest Plan) includes Forest-wide management goals to:

Ø Provide sawtimber and other wood products (including house logs) to help sustain a viable local 

economy. 

Ø Provide firewood for personal and commercial uses.

Ø Provide an economically efficient timber sale program. 

The Forest Plan also includes the Forest-wide management objectives (USDA Forest Service, 1987) to 

offer affordable sales.

Forest-wide standards that supplement the national and regional policies, standards and guidelines found in 

Forest Service Manuals, Handbooks, and the Northern Region Guide relevant to timber harvesting include: 

Ø Providing well designed timber sales to be affordable under average market condition at the time of 

sale.

Section 16 USC 1604(g)(3)(E)(iv) requires that timber will be harvested from National Forests only where 

the harvest system to be used is not selected primarily because it will give the greatest dollar return or the 

greatest unit output of timber. 

Executive Order 12898, issued in 1994 orders federal agencies to identify and address any adverse human 

health and environmental effects of agency programs that disproportionately impact minority and lowincome populations. The Order also directs agencies to consider patterns of subsistence hunting and 

fishing when an agency action may affect fish or wildlife.

The Civil Rights Act of 1964 provides for nondiscrimination in voting, public accommodations, public 

facilities, public education, federally assisted programs, and equal employment opportunity. Title VI of the 

Act, Nondiscrimination in Federally Assisted Programs, as amended (42 U.S. C. 2000d through 2000d-6) 

prohibits discrimination based on race, color, or national origin. 

3.13.3 AFFECTED ENVIRONMENT

A. Community Demographics 

According to the 2000 Census (U.S. Dept. of Commerce 2000), 131,872 people reside in Ravalli and 

Missoula counties. Missoula county has the larger 2000 Census population (95,802) while Ravalli has the 

smaller (36,070). Both counties have experienced population growth since the 1990 Census, and according 

to Census population projections, this growth is expected to continue in the future. Demographically, 

Ravalli County is 96.7% White, 1.9% Hispanic/Latino, 0.9% American Indian, 0.1% Black, and 0.3% 

Asian. Census data reported that the 1999 per capita personal income was $17,935 for Ravalli County. 

The unemployment rate in 2003 was 4.7% statewide and 5.5% in Ravalli County. 

Missoula is a trade center hub which extends to Ravalli County in the south and to Lake County in the 

north. The total employment in the two counties has increased from 58,622 in 1990 to 90,119 in 2003 (US 
Affected Environment & Environmental Consequences - Economics

3.13-4 Lower West Fork Project Final EIS 

Dept of Commerce, Bureau of Economic Analysis, 2005). This is an average annual growth rate of 

approximately 3%. Labor income (2003 dollars) in the two counties has increased from $1,271 million in 

1990 to $2,459 million in 2003 (US Dept of Commerce, Bureau of Economic Analysis, 2005). This is an 

average annual growth rate of approximately 5% (PF-ECON-002). 

In Missoula and Ravalli counties, wood and paper products are an important component of the economic 

base. Wood and paper products account for 16% of the labor income in basic industries in Missoula 

County, and 21% in Ravalli County (Bureau of Business and Economic Research 2005). For Missoula 

County, only trade center services delivered to residents outside Missoula county account for a larger 

percentage of basic industry labor income. For Ravalli County, only commuters account for a larger 

percentage of basic industry labor income. 

B. Bitterroot National Forest Timber Program 

Table 3.13-2 displays a time series perspective of the Bitterroot NF timber program over the last twenty 

years. The timber program on the Bitterroot NF has declined substantially during this period (Fig. 3.13-1, 

3.13-2). There are many reasons for this decline. Some of the decline can be attributed to declining 

budgets, and appeals and litigation. Even at the current harvest levels, volume produced by the Bitterroot 

NF plays a role in the wood and paper products economy of Missoula and Ravalli counties.

Table 3.13- 2: The Trend in Volume Cut and Sold for the Bitterroot National Forest 

and Revenue Received

Year Volume-Sold 

(MBF)

Volume-Cut 

(MBF)

Value-Sold

(2005 $)

Value-Cut 

(2005 $)

1985 39,439 46,569 1,497,363 3,074,534

1995 8,144 6,864 866,533 1,374,682

2005 2,058 5,561 144,141 402,813

0

5

10

15

20

25

30

35

40

45

50

1985 1995 2005

Year

Million Board Feet (MMBF)

Volume-Sold

(MMBF)

Volume-Cut

(MMBF)

Figure 3.13- 1: Trend in Volume Sold 

and Cut on the Bitterroot National 

Forest (1985, 1995 and 2005) 
Affected Environment & Environmental Consequences - Economics

Lower West Fork Project Final EIS 3.13 - 5 

C. Bitterroot National Forest Budget Trend 

Table 3.13-3 displays the total budget for the Bitterroot NF from 2002 through 2006 (Bitterroot National 

Forest 2006). The total budget consists of all budget line items available to fund activities on the Forest. 

The data indicates that the budget decline over the last five years has been very steep. Since 2002, the 

budget has declined by approximately 51%. This budget decline restricts the Forest’s use of appropriated 

funds to accomplish needed work on the Forest. Forest stewardship contracting allows the national forests 

to retain receipts from vegetation projects. The retained receipts can be used for vegetation management 

and required design criteria and other non-timber activities. Given the sharp decline in available budget 

and the amount of restoration work that is needed, the ability to retain receipts through stewardship

contracting provides additional funding opportunities. 

Table 3.13- 3: Total Bitterroot NF Budget in Nominal 

and Real Dollars by Year

3.13.4 ENVIRONMENTAL CONSEQUENCES

A. Project Feasibility 

The estimation of project feasibility was based on the Region 1 transaction evidence appraisal model, 

which took into account logging system, timber species and quality, volume removed per acre, lumber 

market trends, costs for weed spraying, slash treatment, temporary road construction, BMP implementation 

and road maintenance, skid trail rehabilitation, and temporary road decommissioning or storage with 

$0

$500

$1,000

$1,500

$2,000

$2,500

$3,000

$3,500

1985 1995 2005

Year

Value in 2005 Dollars ($1,000s)

Value-Sold 

Value-Cut 

Year Budget ($) Budget (2005 $)

2002 21,892,600 23,563,600

2003 20,992,200 22,145,400

2004 13,989,500 14,380,100

2005 15,168,300 15,168,300

2006 11,730,100 11,496,400

Figure 3.13- 2: Trend in Timber 

Revenue on the Bitterroot National 

Forest (1985, 1995, and 2005)
Affected Environment & Environmental Consequences - Economics

3.13-6 Lower West Fork Project Final EIS 

seeding. The estimated high bid for each alternative, $15.37/CCF and $13.37/CCF, respectively, was 

compared to base rates. Base rate values range between $1.00/CCF for non-sawtimber and $5.00/CCF for 

high value sawtimber. Ponderosa pine sawtimber is a high value tree species. The estimated high bid and 

base rates for each alternative are displayed in Table 3.13-4. The estimated high bids for Alternatives 2 and 

3 indicate that each of the alternatives is feasible (highly likely to sell). The revenue estimates from the 

feasibility analysis are used in the financial efficiency analysis discussed below.

Table 3.13- 4: Project Feasibility and Financial Efficiency Summary (2008 dollars) 

B. Financial Efficiency 

The financial efficiency analysis is specific to the timber harvest and restoration activities associated with 

the alternatives (as directed in Forest Service Manual 2400-Timber Management and the Forest Service 

Handbook 2409.18). Costs for sale preparation, sale administration, regeneration, and restoration activities 

are included. Specialists on the Lower West Fork ID team developed all costs, timing, and amounts. If 

exact costs were not known, the maximum of the cost range was used to produce the most conservative 

PNV result. The expected revenue for each alternative is the volume of sawlog material multiplied by the 

corresponding predicted high bid from the transaction evidence appraisal equation, plus the non-sawlog 

volume multiplied by $1/CCF. There may be opportunities to utilize small material by-products from 

thinning activities for bio-fuels, cellulosic ethanol, and composite lumber, etc. This would provide 

additional revenue and increase the PNV. The PNV was calculated using Quicksilver, an economic 

analysis program based on long-term, actual resource management projects. A 4% real discount rate was 

used over the five-year project lifespan (2010-2014) (PF-ECON-003). 

This analysis is not intended to be a comprehensive benefit-cost or PNV analysis that incorporates a 

monetary expression of all known market and non-market benefits and costs. This type of PNV analysis is 

generally used when economic efficiency is the sole or primary criterion upon which a decision is made. 

Many of the values associated with natural resource management are qualitative and are not assigned a 

monetary value. These qualitative values are factors in the decision and are discussed by resource area in

this document. Changes to resources, like wildlife habitat, have been measured using changes to habitat 

conditions and are not described in financial or economic terms. The wildlife section discusses the value 

trade-offs. Long-term recreation levels are not expected to change between any alternative and were not 

included in the economic efficiency analysis. 

Table 3.13-4 summarizes the project feasibility and financial efficiency, including the base rates, predicted 

high bid (i.e., estimated stumpage value), total revenue, and PNV for each alternative. Because all costs of 

the project are not related to the timber sale, two PNVs were calculated. One PNV indicates the financial 

Category Measure Alternative 1 Alternative 2 (Full) Alternative 3 (Full)

Timber Harvest 

Information Acres Harvested 0 2,494 1,767

Volume 

Harvested (CCF) 0 16,500 11,700

Base Rates 

($/CCF) NA 1.00 – 5.00 1.00 – 5.00

Predicted High 

Bid ($/CCF) NA 15.37 16.37 

Present Value of 

Revenue ($) 0 172,650 123,801

Timber Harvest & 

Required Design Criteria PNV($) 0 -933,864 -726,549

Timber Harvest & All 

Other Planned Activities PNV($) 0 -1,966,013 -1,646,559
Affected Environment & Environmental Consequences - Economics

Lower West Fork Project Final EIS 3.13 - 7 

efficiency of the timber sale, including all costs and revenues associated with the timber harvest and 

required design criteria. The required design criteria, as used here, are: 

1. temporary road construction, and road maintenance, decommissioning, or storage 

2. mandatory stewardship activities (e.g., weed spraying and monitoring, terrace rehabilitation, 

prescribed broadcast burning, pile burning, and subsoiling skid trails), 

3. sale preparation costs, and 

4. sale administration costs. 

A second PNV includes all costs for each alternative, including optional stewardship activities 

(noncommercial thinning, slashing, additional acres of prescribed fire and associated hand line 

construction, piling and burning, terrace rehabilitation, and additional miles of road storage or 

decommissioning) that are not related to timber harvest. The costs used in the PNV calculations can be 

found in Tables 3.13-5 and 3.13-6, with the exception of sale preparation costs ($17/CCF) and sale 

administration costs ($8.50/CCF). Together, sale preparation and sale administration costs are 

approximately $420,750 for Alternative 2 and $286,110 for Alternative 3.

Table 3.13-4 indicates both action alternatives are financially inefficient for the timber sale with design 

criteria and more financially inefficient when the timber sale and all possible stewardship activities are 

combined. The No Action Alternative has no costs or revenue associated with it and in this case has the 

highest PNV ($0). Of the action alternatives, Alternative 3 has a slightly less negative timber sale PNV at 

negative $726,549 compared to negative $933,864 for Alternative 2. When all of the design criteria and all 

of the optional stewardship activities are included, Alternative 3 (Alternative 3Full) has a less negative 

PNV than Alternative 2 Full (- $1,646,559 and - $1,966,013, respectively). 

A reduction of financial PNV in any alternative as compared to the most efficient solution is a component 

of the economic trade-off to achieve that alternative. The No Action Alternative would not harvest nor take 

other restorative actions and, therefore, incur no costs. As indicated earlier, many of the values associated 

with natural resource management are non-market benefits. These benefits should be considered along 

with the financial efficiency information presented here. These non-market values are discussed in the 

various resource sections found in this document. 

Financial efficiency is one tool used to make the decision. Many things cannot be quantified, such as 

increases in the fire management options available to the line officer following treatment, effects on 

wildlife, social impacts to local communities, and restoration of watersheds and vegetation. The decision 

maker considers many factors in making the decision. 

C. Design Criteria Activities and Costs 

Table 3.13-5 displays the design criteria activities with their costs, and the potential available revenue 

needed to pay for those activities. The preliminary available revenue after adjustment for unknowns ranges 

from approximately $100,375 to $139,981 for Alternatives 3 and 2, respectively. The cost of the 

mandatory items not already captured in the TEA appraisals for Alternatives 2 and 3 are $593,197 and 

$721,061, respectively. Differences are due to different harvest volumes, logging system proportions, road 

reconstruction and decommissioning costs, prescribed burning costs, and slash disposal costs between 

Alternative 2 and 3. Funding in addition to the expected revenue from timber sales will be needed to 

achieve mandatory stewardship activities. There may be some additional revenues available from sale of 

small material for bio-fuel, cellulosic ethanol fuel, or composite lumber feedstock. When using the 

predicted high bid multiplied by the volume, then reduced by 25 percent, the mandatory funding needed to 

complete these activities ranges from approximately $492,762 to $581,080 for Alternatives 3 and 2, 

respectively. 
Affected Environment & Environmental Consequences - Economics

3.13-8 Lower West Fork Project Final EIS 

Table 3.13- 5: Activity Expenditures by Alternative over a Five-year Period (2008 dollars) 

Table 3.13-6 displays the optional resource activities not tied to commercial harvest design criteria. It also 

provides an indication of potential funding sources to pay for the activities. The sale of timber in this 

project is the result of commercial and non-commercial thinning to meet a variety of objectives such as 

hazardous fuels reduction, forest resilience to natural disturbance, watershed improvement, and improved 

wildlife habitat. Therefore, in addition to the revenues generated from the sale of associated timber, other 

sources of revenue or appropriated funds must be used to cover the costs associated with the optional 

activities. For activities tied to hazardous fuels reduction, funding from the American Recovery and 

Reinvestment Act may also be available. The costs associated with these optional activities range from 

about $949,147 for Alternative 3 up to $1.08 million for Alternative 2. When these are added to the 

amounts needed to supplement timber revenue for design criteria the result is that unless markets improve 

and/or bids are higher than base rates, it would require roughly $1.657 and $1.442 million in appropriated 

funds or partner funding to complete all of the proposed activities in Alternatives 2 and 3, respectively. 

All of the initial entry prescribed fire and maintenance burn acres in the action alternatives would be 

scheduled for maintenance burns every 6 to 10 years after initial treatments. The first follow-up 

maintenance burn after initial treatment, or when fuel conditions are again appropriate, is analyzed in other 

sections of the EIS and is not included in the economic analysis. 

Alt. 1 Alt. 2 Alt. 3

Available Revenues

Preliminary Advertised Rate ($) * Estimated Volume 0 186,641 133,834

- Adjustment for Potential Underrun (25%) ($) 0 46,660 33,459

Revenue Available for Stewardship ($) 0 139,981 100,375 

Mandatory Activities (not included in the TE Appraisal)

Weed Monitoring ($) 

(Alt 2): 1400 ac @ $5/ac; (Alt 3): 1000 ac @ $5/ac 0 7,000 5,000

Hand Piling, Papering, and Pile Burning ($)

(Alt 2): 128 ac @ $381/ac; (Alt 3): 128 ac @ 381/ac 0 113,157 113,157

Prescribed Underburning ($)

(Alt 2): 2,793ac @ $145/ac; (Alt 3): 1,910ac @ 145/ac 0 402,665 266,655

Handline Construction ($)

(Alt 2: 9,768ft @ $0.80/ft; Alt 3: 8,250ft @ $0.80/ft) 0 7,814 6,600

Road Storage ($)

(Alt 2: 7.5 @ $6500/mi and Alt 3: 4.8 mi @ $6500/mi) 0 48,750 31,200

Road Decommissioning ($)

(Alt 2): 4.1 mi @ $11,000/mi; (Alt 3): 7.0 mi @ $11,000/mi 0 45,100 77,000

Terrace Rehabilitation ($)

(Alt 2 and Alt 3): 148.5 ac @ $350/ac 0 51,975 51,975

Road Maintenance Sites ($)

Alt 2: 2 Sites @ $1,300/site 

Alt 3: 1 Sites @ $1,300/site 

0 2,600 1,300

Skid Trail Subsoiling ($)

(Alt 2): 120ac @ $350/ac, (Alt 3): 115ac @ $350/ac 0 42,000 40,250

Total, Mandatory Activities ($) 0 721,061 593,137

Expected funding needed for Mandatory Activities ($) 0 581,080 492,762
Affected Environment & Environmental Consequences - Economics

Lower West Fork Project Final EIS 3.13 - 9 

Table 3.13- 6: Optional Resource Activities not tied to Commercial Harvest, and their 

Potential Funding Sources

Resource Activity Alt. 2 Alt. 3 Potential Funding 

Sources

Optional Noncommercial thinning ($)

Alt 2: 295ac@ $180/ac 

Alt 3: 295ac@ $180/ac 

53,100 53,100

Appropriated Dollars. 

Given current budgets 

could complete within 1-10 

years

Optional slashing ($)

Alt 2: 4457ac@ $130/ac 

Alt 3: 2960ac@ $130/ac 

579,410 384,800

Appropriated Dollars. 

Given current budgets 

could complete within 1-10 

years

Additional Prescribed and Maintenance 

Burning ($)

Alt 2: 1680ac @ $145/ac 

Alt 3: 1081ac @ $145/ac 

243,600 156,745

Appropriated Dollars. 

Given current budgets 

could complete within 1-10 

years

Additional Hand piling, papering and pile 

burning ($)

Alt 2: 159ac @ $381/ac 

Alt 3: 214ac @ $381/ac 

60,579 81,534

Appropriated Dollars. 

Given current budgets 

could complete 

within 1-10 years

Additional Handline Construction for 

Optional Prescribed Burning, ($)

Alt 2: 2772ft @ $0.80/ft 

Alt 3: 2772ft @ $0.80/ft 

2,218 2,218

Appropriated Dollars. 

Given current budgets 

could complete within 1-10 

years

Additional Road Storage ($)

Alt 2: 11.2mi @ $6,500/mi 

Alt 3: 13.9mi @ $6,500/mi 

72,800 90,350

Appropriated Dollars. 

Given current budgets 

could complete within 1-10 

years

Additional Road Decommissioning ($)

Alt 2: 5.8mi @ $11,000/mi 

Alt 3: 16.4mi @ $11,000/mi 

63,800 180,400

Appropriated Dollars. 

Given current budgets 

could complete within 1-10 

years

Total Optional Activity Costs ($)

Alt 2: 295ac@ $180/ac 

Alt 3: 295ac@ $180/ac 

1,075,507 949,147 

Appropriated Dollars. 

Given current budgets 

could complete within 1-10 

years

 Note: Alternative 1 (has no optional activities and is not shown as all costs are zero)

D. Economic Impacts Effects 

The analysis calculated the jobs and labor income associated with timber harvest and processing and 

conducting mandatory and optional stewardship activities, such as noncommercial thinning, road 

decommissioning, and terrace rehabilitation. Timber products harvested from the proposed project and the 

non-timber activities would have direct and indirect effects on local jobs and labor income. In order to 

estimate jobs and labor income associated with timber harvest, we assumed that 72 % of sawlog material 

would be processed by the sawmill and planing sector for Alternatives 2 and 3. The remaining volume 

would be processed as pulp and paper. We developed expenditures for stewardship activities to estimate 

jobs and labor income associated with them for each alternative (see Table 3.13-5 and Table 3.13-6). 

Table 3.13-7 displays both direct and total estimates for employment (part and full-time) and labor income 

that may be attributed to each alternative. Since the expenditures occur over a four-year period, the 

estimated impacts of jobs and labor income would be spread out over the life of the project. Most of the 

timber harvest and wood processing jobs would occur over the first three years of the project, and most of 

the economic impacts related to the stewardship activities would occur during the later stages of the project. 
Affected Environment & Environmental Consequences - Economics

3.13-10 Lower West Fork Project Final EIS 

It is important to note that these are not new jobs or income, but rather jobs and income that can be 

attributed to this project.

Table 3.13- 7: Total Employment and Labor Income (2006 dollars) Over the Life of the Project

Analysis Item1 Alternative 

1 

Alternative 

2 

Alternative 

3 

Alternative 2 

with all 

Stewardship 

Activities

Alternative 3 

with all 

Stewardship 

Activities

Direct Employment 0 76 53 90 64 

Total Employment 0 151 105 170 121 

Direct Labor Income ($) 0 2,572,000 1,809,000 3,192,000 2,304,000 

Total Labor Income ($) 0 4,855,000 3,381,000 5,636,000 4,011,000 1

Definitions:

Employment is the total full- and part-time wage, salaried, and self-employed jobs in the region.

Labor income includes the wages, salaries and benefits of workers who are paid by employers and 

income paid to proprietors.

Table 3.13-7 provides estimates of direct and total (direct plus indirect and induced) jobs and labor income 

associated with each of the alternatives. Alternative 1 maintains no jobs nor income because there are no 

activities associated with this alternative. 

Table 3.13-7 shows that mandatory activities from Alternative 2 would contribute roughly 76 direct and 

151 total part and full-time jobs, with $2.6 million in direct, and $4.9 million in total labor income, spread 

across the five-year life of the project. We also expect that completing all the optional stewardship 

activities (noncommercial thinning and additional road decommissioning or storage) would contribute an 

additional 14 direct and 19 total part and full-time jobs during a period lasting a little longer than five years. 

An additional $620,000 direct labor income and $781,000 total labor income would be contributed to the 

economic impact area during this period. 

Alternative 3 would not contribute as many jobs as Alternative 2, but substantially more than the No Action 

alternative. For the mandatory work contained in Alternative 3, we expect roughly 53 direct and 105 total 

part and full-time jobs with $1.8 million in direct, and $3.4 million in total labor income, spread over the 

five-year life of the project. Another 11 direct and 16 total part and full-time jobs would be expected

during this period with the implementation of all optional stewardship activities in this alternative. An 

additional $495,000 direct and $630,000 total labor income would be expected above the mandatory work 

proposed in Alternative 3 over a period lasting five years. 

3.13.5 ENVIRONMENTAL JUSTICE AND CIVIL RIGHTS

None of the alternatives restrict or alter opportunities for subsistence hunting and fishing by Native 

American tribes. Tribes holding treaty rights for hunting and fishing on the Bitterroot NF are included on 

the project mailing list and have the opportunity to provide comments on this project. 

Table 3.13-6 above, predicts Alternative 2 and 3 would create more employment and income opportunities 

than Alternative 1. Alternative 2 would have a slightly higher level of opportunity than Alternative 3. 

Implementation of either action alternative would not likely adversely affect minority or low-income 

populations. 
Affected Environment and Environmental Consequences - Scenery

Lower West Fork Project Final EIS 3.14-1 

3.14 VISUAL RESOURCE (SCENERY)

3.14.1 INTRODUCTION

The Lower West Fork analysis area lies in the Bitterroot Mountain Range and is bisected by the West 

Fork Road (State Highway 473). The Lower West Fork road provides access to popular recreation areas 

for fishing, hunting, and river floating in the West Fork of the Bitterroot River area. Compared to other 

parts of the region, the area has high to moderate visual significance. The analysis area is not readily 

visible from the West Fork Road corridor because the terrain is steep or roadside vegetation blocks the 

view. Residents and visitors can glimpse portions of the project area while driving or for longer periods 

where the forested landscape has been converted to meadows. 

3.14.2 REGULATORY FRAMEWORK 

The analysis for this project employs the Visual Management System developed by the U.S. Forest 

Service: Landscape Aesthetics - A Handbook for Scenery Management Number 701 (USDA Forest 

Service 1995c). It is used to analyze and evaluate the visual resource as best available science. This 

system replaces The Visual Management System - Handbook Number 462 (USDA Forest Service 1974). 

The existing Forest Plan was developed with guidelines from the 1974 version. This new system 

provides for the evaluation of physical features of the landscape called "scenic attractiveness classes" 

(formerly - "variety classes") together with the levels of concern people have for scenery (formerly -

"sensitivity levels"). This information is synthesized to develop "Scenic Integrity Objectives" (SIOs),

which were formerly referred to as visual quality objectives (VQOs). 

The Forest Plan established Scenic Integrity Levels (Table 3.14-1) for each Management Area. The 

proposed actions are within a variety of management areas. The guidelines for meeting these SIOs are 

described in Forest Service Handbook #701, A Handbook for Scenery Management, Appendix H.

Table 3.14-1: Scenic Integrity Objectives for Management Areas (USDA Forest Service 1995)

Scenic Integrity 

Objectives Description

Preservation (P) – Very 

High

Refers to landscapes where the valued landscape character is intact with only 

minute, if any, deviations. The existing landscape character and sense of place 

is expressed at the highest possible level.

Retention (R) – High

Refers to landscapes where the valued landscape character "appears" natural. 

Changes may be present but must repeat form, line, color, texture and pattern 

common to the character so completely that they are not evident. 

Partial Retention (PR) - 

Moderate

Refers to landscapes where the valued landscape character "appears slightly 

altered." Noticeable changes must remain visually subordinate to the landscape 

character being viewed.

Modification (M)-Low

Refers to landscapes, which “appear moderately altered.” Changes begin to 

dominate the viewed area, but they borrow attributes such as size, shape, edge 

effect and the pattern of natural openings. They should be compatible or 

compliment the landscape character. 

Maximum Modification

(MM)-Very Low

Refers to landscapes, which “appear heavily altered.” Changes strongly 

dominate the viewed area and they may not borrow attributes such as size, 

shape, edge effect and the pattern of natural openings. Deviations should be 

shaped and blended with the natural terrain so that development does not 

dominate the landscape character. 
Affected Environment and Environmental Consequences - Scenery

3.14-2 Lower West Fork Project Final EIS 

3.14.3 SCOPE OF ANALYSIS AND ANALYSIS METHODS

Field visits, maps, photographs, and GIS software were used to analyze project effects on the scenery 

resource. The scope of this analysis displays the existing condition for the visual resource (scenery) with 

pictures and narrative. The Forest Plan identifies the level of importance for areas within the project 

boundary and displays by Management Area (MA) a Visual Quality Objective (VQO). The analysis will 

show how the existing conditions relate to the visual objectives. Section 3.14.4 (environmental 

consequences section) analyzes the effects of each alternative on the scenery and compatibility with 

Forest Plan direction. 

The routes, which may provide views of the project area, were traveled to determine effects as seen in 

middle and background views. Photographs were taken during field visits for future reference. 

In the office, an analysis using Google Earth to assess views from selected points was used to verify the 

visibility of the project area as determined during field visits and photographs. This led to the selection of 

the key viewpoints. The information gathered from field visits, photographs, and computer analysis was 

combined with the proposed harvest/silvicultural prescription to arrive at the determination of effects on 

the scenery resource and consistency with the Forest Plan. 

The following indicators were used to analyze effects of the alternatives on scenic quality. 

A high impact would have these outcomes.

Ø A large number of people highly sensitive to their surroundings see the vegetation changes in 

foreground and middle ground views; or

Ø The proposed changes dominate the view and/or appear un-natural or chaotic. Vegetation clearing 

presents obvious line contrasts from adjoining forested areas. 

A moderate impact would have these outcomes.

Ø The modifications would be visible to large numbers of people but it is not a dominant element in the 

landscape because forest management activities are commonplace in the area, views are partially 

screened, large segments of the changes may be visible but only for a short time, and/or most views are 

in middle ground or background viewing distance. 

Ø The modifications would change the prevailing land/vegetation patterns but be visible to few people or 

for short periods of time

A low impact would have the following outcomes.

Ø Few viewers would see the area because it is isolated, screened, or seen at a background distance; 

existing conditions have already established impacts.

Ø Road cuts, fills, and clearing would not significantly detract from the setting.

Ø Views would be short-lived and the visually sensitive resource would not be affected.

No impact would have the following outcomes.

Ø No visual changes.

3.14.4 AFFECTED ENVIRONMENT 

The Lower West Fork project is on the West Fork Ranger District on the southern part of the Bitterroot 

National Forest. The area is not readily visible from the West Fork Road corridor because most of the 

lands along the highway are either fully forested or steep and therefore block views into the analysis area. 

Area residents and visitors would glimpse portions of the project area while driving, or where the forested 

landscape has been converted to meadows. The Forest Plan assigns each Management Area scenery 

objectives (Table 3.14-2).

For this analysis, six potential viewpoints were considered including the West Fork Road corridor, the 

Boulder Creek RNA from Sam Billings Campground, West Fork Lodge area, Triple Creek Ranch area, 

Baker Lake trailhead (NFSR 363), and Piquett Creek (NFSR 49). From these initial six viewpoints three 
Affected Environment and Environmental Consequences - Scenery

Lower West Fork Project Final EIS 3.14-3 

key viewpoints were representative of the spectrum of analysis area views, and are the basis of this 

analysis (Table 3.14-3). 

Table 3.14-2: Percent Scenic Integrity Objectives by Management Area in the Lower West Fork Analysis 

Area 

MA (Management Area) VQO SIO

(% of Area)

1 – Timber Emphasis Maximum Modification & Modification 22

2 – Winter Range Modification 24

3A – Visually sensitive areas Partial Retention 18

3C – Visually sensitive areas Retention 1

5 – Semi-primitive Recreation Retention * 12

6 – Proposed wilderness Preservation * 3

6/9 – Proposed wilderness / RNA Preservation * 2

7 – Wilderness Preservation * <1

8A – Minimum level Surrounding area = Retention * 8

9 – Research Natural Area Surrounding area = Partial Retention 1

Private land Not applicable * 9

Grand Total 100

* No treatments are proposed in MA 5, 6, 7, 8A or Private.

The potential viewing locations, including the other three of the six original viewpoints, were not selected 

as viewpoints because field review determined that the Lower West Fork project area could not be seen 

from these locations. Steep topography, dense, mature forest, and private land ownership blocked or 

restricted the view of the immediate foreground (0 to 300 feet), or created buffers between the viewing

and proposed treatments areas.

Table 3.14-3: Viewpoint locations for Lower West Fork Project

Viewpoint # Locations 

1 View from West Fork Lodge/ West Fork road 

2 View from Sam Billings Campground near the Boulder Creek Trailhead 

3 Views from roads accessing the Wilderness (Baker Lake trailhead – NFSR 363)

A. Historical and Existing Conditions 

Natural fires have changed the visual resource of the area throughout history. Historically, fire was the 

primary factor that created the vegetative patterns across the landscape. The typical large-scale pattern 

tended to follow drainage patterns and slopes and varied in intensity, size, and shape. Visual benefits of 

the historical fire patterns included variety in vegetation patterns, horizontal and vertical diversity of 

vegetation structures, and a diversity of plant species.

Fire records indicate that in the late 1800s the Bitterroot National Forest experienced large-scale fire 

events, but no large fires at that time are recorded in the Lower West Fork area. According to fire history 

records for the project area, there have been eighteen wildfires over 100 acres in size since 1889. Most of 

these fires have been at the lower elevations of the analysis area primarily affecting ponderosa pine 

habitat types. The 2007 Rombo fire burned 29,062 acres of which 12,918 acres were within the Lower 

West Fork project area. Most of the area burned in this fire was high elevation Douglas fir and subalpine 

fir habitat types. 

Logging to support the Anaconda Copper Company was extensive in the Lower West Fork area in the 

early 1900s and removed most of the large ponderosa pine (PF-HERITAGE-002). Due to the extensive 
Affected Environment and Environmental Consequences - Scenery

3.14-4 Lower West Fork Project Final EIS 

turn of the century logging, timber harvest by the Forest Service primarily in the 1960s through 1980s, 

ongoing fire suppression, and insect and disease in the area, the tree species and vegetative conditions we 

find now in the project area are very different than what the landscape supported a century ago.

Viewpoints used for this analysis were selected based on the number and sensitivity of viewers and 

opportunities for viewing the management area. Vegetation adjacent to roads and highways plus 

topography combines to screen views of much of the project area (PF-VISUALS). Figure 3.14-1 through 

Figure 3.14-3 display and describe the critical viewpoints used in the scenery effects analysis of the 

proposed management activities. 

Viewpoint Descriptions

Management Area 3c has a Retention VQO meaning management should not be evident because there is 

sensitive foreground and middle ground. Many of these sensitive viewing areas look into or are along

access routes to the Selway-Bitterroot Wilderness...” 

Figure 3.14-1: Viewpoint #1 – West Fork Lodge on West Fork Road 

This section of the highway receives a high degree of use; the sensitivity rating is ‘high’

Visibility is also high from this area.

Prior logging has created shapes and patterns that appear natural and are compatible with visual 

quality objectives.

Viewing duration is moderate to long.
Affected Environment and Environmental Consequences - Scenery

Lower West Fork Project Final EIS 3.14-5 

Figure 3.14-2: Viewpoint #2 - From Sam Billing Campground –

Boulder Creek RNA

Figure 3.14-3: Viewpoint #3 - From West Fork Road Looking Towards Triple Creek

The Lower West Fork project area offers distinctive and quality scenery. Most of the area meets or 

exceeds the Forest Plan scenery objectives. 

Summary

This site receives a 

high degree of use; 

and the sensitivity 

rating is high. 

Visibility of the 

proposed RNA 

treatment unit is low 

from this location. 

Viewing duration is 

brief to moderate.

Viewpoint is 

located on 

West Fork 

Hwy. 

The 

sensitivity 

rating is high. 

This area 

provides a 

limited view 

of treatment 

units. 

Viewing 

duration is 

moderate
Affected Environment and Environmental Consequences - Scenery

3.14-6 Lower West Fork Project Final EIS 

3.14.5 ENVIRONMENTAL EFFECTS

A. Direct and Indirect Effects

About 46 percent of the area is within management areas 1 and 2, which under the Forest Plan can

‘appear moderately or heavily altered’. Units in management area 3a or that have a Partial Retention SIO 

would have landscapes that "appear slightly altered. Noticeable changes must remain visually 

subordinate to the landscape character being viewed.” Proposed treatments occur in management areas 1, 

2, and 3a.

Prescribed fire units would meet Forest Plan visual quality guidelines. Fire effects on the landscape, 

whether human or natural ignition, are usually perceived as natural. Some activities associated with 

prescribed fire, such as slashing and fire line construction, may introduce form and lines to the landscape; 

however, these features would not be visible from the West Fork Road, except in Unit 100. The visual 

effect would last until treatment is complete. 

Approximately 10 percent crown cover would be removed in units treated exclusively with low intensity 

fire and about 25% crown cover in the moderate intensity fire units, 61A and 32. Travelers on the West 

Fork Highway would see scorched lower branches and individual or small pockets of dead trees. In the 

background on the upper slopes, larger pockets of dead trees would be visible. The visual effects of 

prescribed fire would be transient and would fade within 2-5 years of treatment. This level of canopy loss 

would not be noticeable to most of the people traveling the West Fork Highway.

Effects of harvest activities in portions of the proposed units would be visible from the key viewpoints 

along the West Fork Road. Silvicultural prescriptions would remove 25 to 60 percent of the standing 

vegetation, depending on original stand density, tree size, and target basal area, or up to 30% of the 

canopy. Some travelers on the West Fork Highway may notice the more open forest structure. Changes

in vegetation would be most evident in areas with high stocking and multiple layer canopies and less 

evident in areas with lower stocking. Scenery changes would borrow attributes such as size, shape, and 

edge from the pattern of natural openings. Thinning the units from below would retain continuous forest 

canopy with a few more or larger natural openings. This type of treatment will not create a visual effect 

noticeable to most forest visitors or travelers along the West Fork Road. Most of the treated scenery will 

be in the middle and background views and visual effects would be low. The growth of the remaining 

tree crowns and understory vegetation over several years would moderate any visual effects. 

Timber harvest has potential to impact the visual resource in units 2, 3, 4, 8, 9, 10, 11, 12, 18, 20, 42, and 

61. Skyline corridors within units 2, 3, 9, 42, and 61 would have the most visual impact from the West 

Fork Road. Skyline corridors would be laid out to take advantage of natural openings and minimize the 

number of leave trees damaged during yarding. Equipment capabilities for lateral yarding and removing 

damaged leave trees would soften the edge effect of the corridor. In approximately 1-5 years, ground 

vegetation will recover and the visual effects of harvest would not be noticeable. Therefore, visual 

impacts of timber harvest would be low and would meet Forest Plan visual quality objectives.

On the west side of the West Fork Road, the effects on visual quality would be the same in Alternatives 2 

and 3. There would be no effects on the east side of the West Fork Road under Alternative 3 but 

treatment effects of Unit 42 would be visible under Alternative 2. There would be no immediate changes 

in visual quality under Alternative 1. 

B. Cumulative Effects

Treatment effects would coincide with those of Frasier and School Point fuel treatments. Small patches 

of tree mortality from Frasier and Schoolhouse point would fade by the time Lower West Fork units 

would be treated. Changes in the texture and form of continuous green forest would increase as the 

pockets of tree mortality fade and create snags or small openings. Forest cover, viewed from the West 
Affected Environment and Environmental Consequences - Scenery

Lower West Fork Project Final EIS 3.14-7 

Fork Road, would appear continuous with openings of various sizes. The appearance would be natural 

and meet Forest Plan visual quality objectives. 

Looking up Piquett Creek, a viewer on West Fork Road can glimpse a pocket of snags on the horizon 

remaining from the Rombo Fire. The effects of the fires in 2000 are visible on the east side of the West 

Fork Road in the northern part of the analysis area. The area appears sparsely forested with openings of 

shrubs and some residual snags. The Lower West Fork units would mimic this appearance though the 

forest would be more continuous and the openings would not be as large.

Timber harvest in Trapper Bunkhouse Land Stewardship Project would coincide with timber harvest 

proposed in Lower West Fork Project. However, the units in these sales that are adjacent are not visible 

from the West Fork Road. Therefore, there would be no cumulative effects on visual quality as seen from 

the viewpoints on the West Fork Road. 

3.14.6 CONSISTENCY WITH FOREST PLAN, LAWS, AND REGULATIONS

All three alternatives would meet the Forest Plan visual quality objectives. 
Affected Environment and Environmental Consequences – Human Health and Herbicide Use

Lower West Fork Project Final EIS 3.15-1

3.15 HUMAN HEALTH AND HERBICIDE USE

3.15.1 REGULATORY FRAMEWORK

Safety standards for herbicides use are set by the Environmental Protection Agency, Occupational Health 

and Safety Administration, Code of Federal Regulations (40 CFR part 170), and individual states. In 

addition, several sections of the Forest Service Manual (FSM, 1994) provide guidance to the safe handling 

and application of herbicides. These include:

Ø Preparation of a safety plan for all pesticide use projects (FSM 2150)

Ø Consultation of pesticide handling requirements set forth in the Forest Service Health and Safety 

Code Handbook (FSM 6709.11) and (FSM 2156)

Ø Pesticide-Use Management and Coordination Handbook that requires the Forest to review pesticide 

use proposals in terms of human health (FSM2109.13.2)

Ø Recommendation to complete risk assessments prior to pesticide use to ensure public safety (FSM 

2109.14)

Ø Completion of project work plans prior to implementation, including a description of personal 

protective clothing and equipment required (FSM 2109.14.3)

Ø Safety planning the requires development of a safety plan to protect the public and employees from 

unsafe work conditions when pesticides are involved (FSM 2109.16, FSM 2153.3)

Ø Safety and Health Hazard Analysis that requires completion of a Job Hazard Analysis (Form FS67007-7) to determine hazards on the project and identify ways to eliminate them (FSM 2109.16.2, 

FSM 6700, FSH 6709.11)

Finally, FSM 2109.16.3 states the requirement for, and defines Pesticide Risk Assessment as “Another

method of helping to ensure safety in pesticide use is to conduct risk assessments. Analyses estimate the 

possible pesticide dose to workers and the public who may be affected by a pesticide application; and the 

potential effects on fish, wildlife, and other non-target organisms. These estimated doses are then 

compared with levels of no observed effects based on tests of laboratory animals.”

3.15.2 AFFECTED ENVIRONMENT

The human health environment overlaps the project area. The social categories of humans that may be 

potentially affected by weed control actions in Alternative 2 include:

Ø workers applying the herbicide

Ø logging professionals associated with the project

Ø Forest Service personnel involved in post-logging treatments or inspections

Ø recreationists walking through treated areas (e.g. skid trails, system trails, roadsides, etc.)

Ø berry-pickers or plant gatherers using areas that have been sprayed

Ø private landowners that may use areas adjacent to treated National Forest

The effects of weed control actions involve both impacts of invasive plants on humans and the impacts of 

weed control actions, primarily herbicide applications, on humans. Herbicide concerns focus on human 

exposure to toxicants found in the weed control chemicals.

A. Method of Analysis

The Forest Service contracted with Syracuse Environmental Research Associates (SERA) to evaluate 

ecological and toxicological data and human health effects based on Environmental Protection Agency 

(EPA) studies and other current peer-reviewed scientific literature. 

The analysis methodology found in the Selway-Bitterroot Wilderness Invasive Plants Management Project 

Draft Environmental Impact Statement (SBW Weeds DEIS 2008d) is incorporated by reference into The 

Lower West Fork project analysis. The SBW Weeds DEIS contains a detailed description of risk 
Affected Environment and Environmental Consequences – Human Health and Herbicide Use

3.15-2 Lower West Fork Project Final EIS 

assessment scenarios in Section 3.8.3 of that document. Human health and safety risks for the use of 

herbicides in this analysis are based on SERA Human Health and Ecological Risk Assessments (RAs) and 

other documents. The SERA RAs are incorporated into the SBW Weeds DEIS analysis (and the Lower 

West Fork Project by reference). The RAs are summarized in and can be found at

Huckleberry plants are the most common wild food available for collection in the Lower West Fork Project 

Area. The contamination scenarios for wild foods discussed in the SBW Weeds DEIS also apply to this 

project.

http://www.fs.fed.us/foresthealth/pesticide/.

3.15.3 ENVIRONMENTAL CONSEQUENCES: DIRECT,INDIRECT, AND CUMULATIVE 

EFFECTS

Alternative 2 proposes the use of herbicides in the list of actions and mitigations measures. Only 

herbicides reviewed and registered with the Environmental Protection Agency (EPA) would be used. Table 

3.15-1 provides a description of herbicides commonly used for projects like the Lower West Fork project 

and is taken from the SBW Weeds DEIS Table 3.1-6 (USDA Forest Service 2008d). 

Table 3.15-1: Comparison of Potential Herbicides Used in the Lower West Fork Analysis Area

Chemical/Brand 

Names/Mode of Action

Properties General Uses/Known to be 

Effective on:

Comparisons/Issues

2,4-D / (Weedone, Weedar, 

many more) Synthetic auxin 

- Mimics natural plant 

hormones.

Readily absorbed 

through leaves or 

roots. Accumulation 

is primarily in the 

young, rapidly 

growing meristematic 

regions of roots or 

shoots.

Readily absorbed and 

metabolized. Used for the 

control of many broadleaf 

species. 

Half-life in soil is usually not 

longer than 1 or 2 weeks 

during the growing season due 

to rapid decomposition by soil 

micro-organisms.

Amines and esters are the 

most common formulations of 

2,4-D. The esters are the most 

active and can be used at the 

lower rates and for brush 

control. Since vapor drift is a 

potential problem with the 

ester formulations, only the 

amines should be used in 

susceptible lawn, garden, or 

crop areas. Low-volatile esters 

can be used in areas where 

risk of damage to sensitive 

non-target vegetation is low.

Aminopyralid (Milestone)

pyridine carboxylic acid

auxinic growth regulator -

disrupts plant growth 

metabolic pathways

Aminopyralid 

provides systemic 

postemergence 

control

Broad-spectrum control of a 

number of key noxious and 

invasive annual, biennial 

and perennial weed species, 

as well as agronomic 

broadleaf weeds. 

Aminopyralid can also 

provide residual weed 

control activity controlling 

re-infestations and reducing 

the need for re-treatment 

depending on the rate 

applied and the target 

weeds. 

It provides broad-spectrum 

broadleaf weed control at very 

low labeled use rates (4 to 7 fl 

oz/acre, or 0.06 to 0.1 lb 

ae/acre), compared to 

currently registered herbicides 

with the same mode of action, 

including 2,4-D, clopyralid, 

triclopyr, picloram and 

dicamba.

Can be applied up to the 

water’s edge

Chlorsulfuron Glean -Selective Use at very low rates on Safe for most perennial 
Affected Environment and Environmental Consequences – Human Health and Herbicide Use

Lower West Fork Project Final EIS 3.15-3

Chemical/Brand 

Names/Mode of Action

Properties General Uses/Known to be 

Effective on:

Comparisons/Issues

(Telar,Glean,Corsair) 

Sulfonylurea-Interferes with 

enzyme acetolactate synthase 

w/ rapid cessation of cell 

division and plant growth in 

shoots and roots.

preemergent or early 

postemergent

Telar – Selective preand post-emergent.

Chlorsulfuron can be 

used for many 

annual, biennial and 

perennial broadleaf 

species.

annual, biennial and 

perennial species; especially 

Canada thistle, dalmation 

toadflax, hounds tongue and 

perennial pepperweed. 

Safe for most grasses.

grasses and conifers. 

Some soil residual. Potential 

for offsite movement through 

runoff or wind erosion is 

substantial in conditions that 

favor these actions. 

Damage to some aquatic 

plants possible at peak 

concentration. 

Without drift mitigation 

(selective spot hand treatment, 

etc.), offsite drift from ground 

broadcast application may 

cause damage to non-tolerant 

species up to 900 feet. 

Clopyralid / (Transline) / 

Synthetic auxin –Mimics 

natural plant hormones. 

Similar to picloram. 

Contains hexachlorobenzene.

A highly translocated, 

selective herbicide 

active primarily 

through foliage of 

broadleaf species. 

Little effect on 

grasses.

Particularly effective on 

Asteraceae, Fabaceae, 

Polygonaceae, Solanaceae. 

Some species include 

knapweeds, yellow 

starthistle, Canada thistle, 

hawkweeds.

Not as persistent as picloram. 

Can persist from one month to 

one year. More selective than 

picloram.

Potentially mobile depending 

on site specific conditions. 

Dicamba / (Banvel , 

Vanquish)

Synthetic auxin -Mimics 

natural plant hormones

Readily absorbed by 

roots, stems or leaves 

and then translocated 

to other plant parts. 

Control is best when 

weeds are small and 

actively growing.

Used for the control of a 

variety of broadleaf and 

woody vegetation. 

Particularly effective against 

bindweed and Canada 

thistle.

Spray drift is toxic to nontolerant plants in the same 

manner as 2, 4-D, thus similar 

precautions should be 

followed. 

Banvel is more likely to 

generate dicamba vapor than 

Vanquish.

Dicamba is often mixed with 

grass herbicides or with 

phenoxy herbicides to provide 

a broader spectrum of weed 

control.

Glyphosate (RoundUp, 

Rodeo etc.) 

Inhibits three amino

acids and protein

synthesis.

A broad spectrum, 

nonselective

translocated herbicide 

with no apparent soil 

activity. Translocates 

to roots and rhizomes 

of perennials. 

Adheres to soil which 

lessens or retards 

leaching or uptake by 

non-targets.

Low volume applications 

are most effective. Control 

for purple loosestrife, reed 

canarygrass and other weeds 

common in wetland and 

riparian habitats.

Aquatic formulations can be 

used near water. Rain within 6 

hours of application may 

reduce effectiveness. 

Complete control may require 

re-treatment. Without drift 

mitigation (selective spot hand 

treatment, etc.), off site drift 

damage from ground 

broadcast application to nontolerant species up to 100’ 

possible.

Imazapic / (Plateau) / Inhibits 

the plant enzyme 

acetolactate, which prevents 

protein synthesis.

Selective against 

some broadleaf plants 

and some annual 

grasses.

Use at low rates can control 

leafy spurge, cheatgrass, 

and hounds tongue.

Useful in grassland prairie 

habitat restoration because it 

is selective against annual 

Without drift mitigation 

(selective spot hand treatment, 

etc.), off site drift from ground 

broadcast application may 

damage non-tolerant species 

up to 50’ possible
Affected Environment and Environmental Consequences – Human Health and Herbicide Use

3.15-4 Lower West Fork Project Final EIS 

Chemical/Brand 

Names/Mode of Action

Properties General Uses/Known to be 

Effective on:

Comparisons/Issues

grasses. Even very tolerant species 

could be damaged directly. 

Some damage to aquatic 

plants at peak concentrations.

Metsulfuron methyl / 

(Escort) / Sulfonylurea –

Inhibits acetolactate

synthesis, protein

synthesis inhibitor,

block formation of

amino acids.

Selective against 

broadleaf and woody 

species. Most 

sensitive crop species 

in the Lily family.

Use at low rates to control 

such species as 

houndstongue, perennial 

pepperweed, sulfur 

cinquefoil. 

Safest sulfonylurea around 

non-target grasses.

Potentially mobile in water or 

through wind erosion. 

Damage to some aquatic 

plants possible at peak 

concentrations. Without drift 

mitigation (selective spot hand 

treatment, etc.), off site drift 

from ground broadcast 

application may cause damage 

to non-tolerant plants up to 

500’.

Picloram (Tordon)

Restricted Use Herbicide

Contains

hexachlorobenzene.

Selective, systemic 

for many annual and 

perennial broadleaf 

herbs and woody 

plants.

Use at low rates to control 

such species as knapweeds, 

Canada thistle, yellow 

starthistle, houndstongue, 

toadflaxs, St. Johnswort, 

sulfur cinquefoil and 

hawkweeds.

Also can leak out of roots to 

non-targets. One application 

may be effective for 2 or more 

years. Can move offsite 

through surface or subsurface 

water. Can be relocated 

through livestock urine.

Sulfometuron methyl (Oust) 

Sulfonylurea - Inhibits 

acetolactase synthase, a key 

step in branch chain amino 

acid synthesis.

Broad spectrum preand post-emergent 

herbicide for both 

broadleaf species and 

grasses.

Used at low rates as a preemergent along roadsides. 

Known to be effective on 

canary reedgrass (but not 

labeled for aquatic use), 

cheatgrass and medusahead.

Highly mobile by water or by 

wind erosion. Substantial 

damage has occurred to 

croplands in arid and wet 

regions. Damage to some 

aquatic plants possible at peak 

concentration

Triclopyr / (Garlon, 

Pathfinder, Remedy) / 

Synthetic auxin - Mimics 

natural plant hormones.

A growth regulating 

selective, systemic 

herbicide for control 

of woody and 

broadleaf perennial 

weeds.

Little or no impact on 

grasses. Effective for many 

woody species such as basal 

bark or cut stump treatment 

for salt cedar.

Garlon 4 (ester compound) is 

toxic to fish and aquatic 

invertebrates. Amine 

formulations may be used near 

or over water. Offsite 

movement by water possible. 

The full analysis of the risks and potential effects to the general public and workers from herbicides is 

incorporated by reference into this document from the SBW Weeds DEIS, Section 3.8.4. This analysis fits 

the weed control actions proposed in the Lower West Fork Project Alternative 2 and a summary of effects 

follows. Herbicide application workers are exposed to many of the same hazards as manual workers when 

working in an outdoor wildland environment. 

The reference dosage (RfD) for chronic exposure is a very conservative toxicological threshold in relation 

to this analysis because it assumes daily exposure over a 70-year lifespan. Actual potential environmental 

exposures for the projects in this analysis for both workers and the general public would not be every day 

for 70 years. The chronic RfD is used to err on the side of caution. Actual chronic effects are less when

exposure is less. RAs were used to evaluate whether worker or public exposure scenarios could potentially 

exceed the RfD. The RA scenarios consider only risks associated with the herbicides themselves. 

Judgments about the potential hazards of herbicides to humans are based, in large part, on the results of 

toxicity tests on laboratory animals. Information on actual human poisoning incidents and effects on 

human populations supplements the laboratory animal test results, where such information is available. 

The RA combines the inherent hazard of the herbicide, an estimate of exposure, and a dose-response 
Affected Environment and Environmental Consequences – Human Health and Herbicide Use

Lower West Fork Project Final EIS 3.15-5

assessment to generate an estimate of risk for each scenario for each chemical – referred to as the Hazard 

Quotient (HQ). The HQ is the ratio of the amount of herbicide received from a particular exposure scenario 

to the RfD (estimated dose/RfD). When a predicted dose is less than the RfD, then the HQ is less than 1.0, 

and significant toxic effects are unlikely for that specific herbicide application. 

For aminopyralid, a potential exposure scenario was analyzed based on treatment of vegetation around 

campgrounds or other recreation areas. An analysis of a short-term post-application incidental oral 

exposure for infants and children via hand-to-mouth transfer of residues and ingestion of aminopyralidcontaminated grass and soil resulted in an exposure estimate 150 times below the acceptable limit. 

Triclopyr had four general public worst-case scenarios with HQs greater than 1. These scenarios were:

1. direct spray of a naked child who does not wash off the herbicide for 1 hour

2. a woman being directly sprayed on her lower legs and feet and not washing it off for 1 hour

3. a child drinking l liter of water from a pond where 200 gallons of mixed herbicide was spilled

4. a woman walking through a recently sprayed area wearing shorts for 1 hour and not washing for 24 

hours 

The first three scenarios are highly unlikely because the typical application rates are much lower than in the 

scenarios, applicators are trained in situational awareness and never directly spray a person, areas of 

herbicide use are posted, and precautions would be taken following a spill to prevent public access. The 

HQ for the fourth scenario was relatively low, 1.3, indicating that while it may be plausible, protection 

measures would reduce the likelihood and in the event it occurs, the exposure is very close to the 

conservative EPA RfD (USDA Forest Service 2008d). 

Four of the herbicides: chlorsulfuron, imazapic, sulfometuron methyl, and picloram have an HQ of less 

than one for all scenarios evaluating applicator exposure, which indicates significant toxic effects are 

unlikely. For the typical application rates, only one of the herbicides (2,4-D) exceeds an HQ of 1. These 

scenarios are for general exposure from backpack (HQ = 1.3) or ground (HQ = 2) applications (USDA 

Forest Service 2008d). The exposure scenarios are mitigated and unlikely to occur because applicators will 

apply herbicides, at most, 30 to 40 days a year (usually less) for a maximum 20 to 30 year career, instead of 

daily exposure for 70 years. In addition, workers wear personal protective equipment and observe safe 

herbicide handling practices. The acute exposure scenarios are a worker wearing contaminated gloves for 1 

hour (HQ = 1.7) and a worker spilling herbicide on their lower legs and not washing it off for 1 hour I HQ 

= 2). Both of these scenarios have relatively low HQs that are close to 1. There is a low likelihood of these 

scenarios occurring because applicators carry clean wash water on the job, and are instructed to wash 

immediately upon contamination or spilling herbicide on themselves. Six of the herbicides: chlorsulfuron, 

clopyralid, glyphosate, imazapic, sulfometuron methyl, and picloram have HQs of less than one for all 

scenarios (USDA Forest Service 2008d). 

The No Action Alternatives and Alternative 3 would have no herbicide related direct, indirect or 

cumulative effects on human health. 
Response to Comments

Lower West Fork Project Final EIS 4-1

CHAPTER 4.0 

LOWER WEST FORK DEIS RESPONSE TO COMMENTS

4.1 INTRODUCTION

The Forest Service solicited comments on the Lower West Fork Project Draft Environmental Impact 

Statement (DEIS) from April 10, 2009 through May 26, 2009. The ID Team and Deciding Officer read all 

of the letters received from organizations, government entities, and individuals and identified the 

comments. The responses to the comments follow below. The comments are highlighted in gray, bolded 

and numbered. Following the comment is the Forest Service response. Copies of the entire comment letters 

are included in this chapter following the comments and responses section.

The following table shows the names and comment codes assigned to the letters for everyone who 

submitted comments on the DEIS.

Name Comment Code

Log Cabin Environmental Consulting, LLC LCEC

Bitterroot Adventures BA

Lost Trail Powder Mountain - Bill Grasser LTPM

Craig E. Thomas CT

Smurfit-Stone Container SSC

Friends of the Bitterroot & WildWest Institute FOB/WWI

United States Environmental Protection Agency USEPA

United States Department of the Interior No comments

4.2 COMMENTS AND RESPONSES

LCEC-1. I would like to compliment the Forest Service for trying to improve forest health, fisheries 

and soil stability on 5,100 acres in the lower West Fork. The majority of this project appears to be 

well-planned for the benefit of the forest and wildlife and will have little impact on the public with 

the exception of the use of fire.

Thank you

LCEC-2: I am concerned that the Forest Service continues to use prescribed fire, underburns of 

slash and slash pile burns. I would like for you to adopt a "no prescribed burns or slash burns or 

open burning policy' in Ravalli County.

I believe that our government should set a good example for the public by implementing practices 

that aggressively protect our environment and public health.

...why should a government agency, or anyone for that matter, continue to voluntarily burn and 

cause air pollution

The Lower West Fork Project FEIS is a site-specific analysis of the effects of applying the Forest Service 

fire use policies. It does not address making policy. 

The Interdisciplinary team (ID Team) considered an alternative that would reduce fuel through timber 

harvest but not use fire to treat the resulting slash (FEIS pg. 2-17). Slash could be ground into chips, which 

would require whole tree yarding. The nearest market is 100 miles from the analysis area and is a limited 
Response to Comments

Lower West Fork Project Final EIS 4-2

option at this time. In addition, chip vans have a wider turning radius than typical log trucks and may not 

be able to access some units. Under Alternatives 2 and 3, chipping is an option if the market is available 

and the units are accessible (FEIS pg. 2-8, 2-14). 

This alternative would not treat the prescribed fire only units, which would maintain pathways by which 

fire could threaten resources in and adjacent to the WUI. It would not reduce fuel loads adequately and 

may increase fuel loads in some situations. Therefore, it would not meet the purpose of reducing fuel loads 

and lowering crown fire hazard. Not treating the prescribed fire units would decrease the fuels 

management effectiveness at the landscape-level (Arno and Fiedler 2005, Finney et al. 2005). 

Arno et al. state (1995) ―Cutting without subsequent burning is ineffective for forest restoration because 

only fire can efficiently remove large proportions of the small understory trees that occupy managed stands 

and which if not removed, will develop into thickets of stressed trees. In addition, fire produces unique

changes in soil chemistry such as increased pH and rapid oxidation of nutrients, both of which may 

significantly influence nutrient availability.‖

The benefit of using prescribed fire is that they are ignited only when favorable smoke dispersal conditions 

are forecast. The Forest Service employs Best Available Control Technology (FEIS pg. 3.4-5) to limit the 

production and persistence of smoke in populated areas. These practices reduce the potential for the 

concerns raised in this issue. Results from the Smoke Impact Spreadsheet and CALPUFF modeling (FEIS 

pgs. 3.4-8 thru 12) indicate the level of particle pollution would be below 35ug/m3, the National Ambient 

Air Quality Standard for Particle Pollution (Table 3.4-2, FEIS pg. 3.4-9). Additionally, modeling results 

indicate that most of the fine particles (particulate matter less than 2.5 micrometers in diameter (PM2.5))

will be concentrated within 0.1 mile of the prescribed fire units (Figs. 3.4-5 and 3.4-6, FEIS pgs. 3.4-10.and 

3.4-11), which are located away from population centers. 

LCEC-3: I am concerned about air pollution from any source. And, I am very concerned that 

government agencies continue to use open burning when Ravalli County has been knocking on the 

door of air quality nonattainment status for several years.

Ravalli County is near non-attainment status (has exceeded or is close to exceeding NAAQS for fine 

particulates for many of the last 5 years) and subject to inversions in a narrow mountain valley,...

When we discussed the air monitoring data and results that exceeded air quality standards for 2004 

and 2005, many Ravalli County residents pointed at the Forest Service as the pollution source.

The DEIS does not even mention that Ravalli County is near non-attainment status for air quality. I 

believe the DEIS needs to more seriously address the alternatives to burning with our health in mind.

Ravalli County is not currently in non-attainment status. Montana Airshed 4 includes all of Ravalli County 

(FEIS pg. 3.4-1). The Montana Department of Environmental Quality has designated Montana Airshed 4 

as an attainment area (FEIS 3.4-6). The FEIS does not specifically mention Ravalli County as a nonattainment area but does state, ―The Lower West Fork project area lies entirely within Montana Airshed 4. 

National Air Quality Standards for fine particulates are shown in Table 3.4-1 (FEIS pg. 3.4-4). The State 

of Montana requires all users of prescribed fire to apply Best Available Control Technology as described 

on page 3.4-5 of the FEIS. The effects analysis shows the proposed prescribed burning treatments will 

produce low amounts of PM2.5 and have minimal visibility and health effects beyond 0.1 miles from the 

treatment locations (FEIS pg. 3.4-8). Based on this analysis the proposed treatments would not cause

Airshed 4 to reach non-attainment status. 

Air Quality Index Charts from 2000 to the present (http//www.epa.gov) indicate air quality standards were 

exceeded in 2000, 2003, 2005 2006, and 2007 during August. Fine particulates at this time of year would 

be from wildfires. There were no instances of exceeding or approaching air quality standards between 

March and July, the months in which prescribed fires are typically ignited. Air quality standards were 

exceeded infrequently between December and February, which would be associated with weather 
Response to Comments

Lower West Fork Project Final EIS 4-3

inversions and burning wood for heat (FEIS pg. 3.4-5 thru 3.4-7). Due to the poor smoke dispersion during 

the winter, Airshed 4 is closed to open burning during the months of December, January and February.

LCEC-4: ...recently the air monitoring results showed unhealthy health effects for hourly air 

monitoring in March.

March 12 was the only day in 2009 when average hourly particulate levels peaked at 109 μg/m3 at 10:00 

pm (2200 hours). A review of the Montana/Idaho Airshed Group Smoke Monitoring Unit‘s database and 

the Hamilton dispatch radio logs shows that there were no prescribed burns conducted by the Forest 

Service on that date (personal comm. Lubke 2009). 

LCEC-5: I believe you can accomplish your fuel reduction goals without prescribed burning and 

slash burning.

Prescribed burning is one method the Forest Service uses to reduce fuels. We endeavor to sell the excess 

fuel as sawlogs, chips, or other small wood products (FEIS 2-5, 2-8 –2.13). We also retain coarse wood 

and some fine woody material (as long as it does not create high fuel loading) on site for soil productivity

purposes (FEIS pg. 3.5-13). However, these other methods of reducing excess fuels do not always meet the 

objectives and the Forest Service must use prescribed fire. 

Stephens et al. (2009) shows the importance of using prescribed fire after mechanical treatments in order to 

increase the treatment effectiveness of reducing potential fire severity under severe weather conditions. 

―Across all fire and fire surrogate sites using mechanical treatments, the relative potential for active crown 

fire (as measured by the crowning index) was lowest in mechanical plus fire treatments, followed by the 

mechanical-only treatments, closely followed by fire-only treatments (fall or spring), and highest in the 

controls (Fig. 3).‖ (Stephens et al. 2009: pg. 310). Their results also show that areas only treated by 

mechanical means had higher tree mortality under severe weather conditions than those that used a 

combination of mechanical and prescribed fire.

LCEC-6: ...why the environmental impact analysis did not provide statistics on how many wildfires 

were caused by slash piles or prescribed burns or open burning. Are you really reducing the wildfire 

potential by burning? Would thinning, harvesting, composting, chipping or other methods work just 

as well or better than burning?

The Forest Service uses all the methods listed above in LCEC-5 to reduce fuels but they are not always 

adequate to meet the fuel reduction needs. Often there are no markets for fuels created by timber harvest or 

thinning, leaving prescribed fire as the most cost effective methods of removal. Stephens et al. (2009) 

shows the importance of using prescribed fire after mechanical treatments in order to increase the treatment 

effectiveness and reduce potential fire severity under severe weather conditions (See LCEC-5 above). 

All prescribed fire has the potential for escape; however, the preparation described in the proposed action 

would sufficiently reduce the potential by removing ladder fuels and increasing crown spacing. The 

Bitterroot National Forest (Bitterroot NF) has used prescribed fire on an average of 3,200 acres per year 

since 1991. In the past 17 years only two prescribed fires have escaped control lines and were declared 

wildfires, the Overwhich Fire in 1991, and the Beaver Woods Fire in 2004. Both of these fires were being 

conducted in activity fuels and were in the final stages of mop-up when an unpredicted high wind event 

occurred. No prescribed fires in natural fuels (―eco-burns‖) have ever escaped control on the Bitterroot NF.

Within the Lower West Fork project area, 81% of the fires since 1970 were started by lighting and 19% 

were human caused (FEIS 3.3-8—3-8-10). According to Bitterroot NF fire history, only one human-caused 

fire originated from debris burning since 1986 (Bitterroot NF GIS database). This fire occurred in 1992, on 

private land and was 1/10th of an acre in size. 

LCEC-7: Where is the economic analysis that compares the cost of burning to the cost to our health? 

The health impacts should not just be an evaluation of hospital visits. It should include the cost of 

missed sports workouts, young children with asthma with increased costs of medical treatment, 
Response to Comments

Lower West Fork Project Final EIS 4-4

young athletes having heart attacks, children without respiratory disease having bronchitis and 

having to use inhalers after poor air days, adults with even mild respiratory disease that have to stay 

inside or miss work when someone is burning slash or conducting prescribed burns.

We have not evaluated health impacts or their costs for two main reasons. The first is because most human 

health problems listed, (including asthmatic attacks, missed work, missed sports workouts, etc. ) are 

associated more with smoke and particulate matter from either a single large wildfire, or multiple wildfires 

during fire season inversions, than with prescribed fires or slash pile burning (Ottmar and Hessburg 1996). 

The second reason is that evaluating healthcare and the other costs would require a long list of complicated 

assumptions and lead to a purely speculative analysis. 

Instead of constructing this type of analysis, the Forest Service mitigates smoke impacts as much as 

possible. We reduce the size of uncontrollable wildfires through a combination of mechanical thinning and 

prescribed fire, which collectively reduce the extent and intensity of future wildfires. Furthermore, the 

plans listed in the Lower West Fork FEIS include managing the landscape with prescribed fires only when 

air conditions are forecast for good smoke dispersal. The Forest Service applies Best Available Control 

Technology (FEIS pg. 3.4-5) to limit the production and persistence of smoke in populated areas and

reduce the potential health concerns raised above. See also response at LCEC-2.

LCEC-8: ...we could create more jobs by cutting the trees and chipping the slash rather than 

burning it.

Please consider eliminating prescribed burns and the practice of slash burning.

Tree harvest and utilization, and other methods of reducing or treating slash are part of the proposals for 

each of the action alternatives (FEIS 2-5—2-10, 2-12—2-14). Wood products industries have expressed 

interest in slash utilization and sales are designed to facilitate this utilization when possible. 

However, there is a reason to include prescribed burns as part of the fuel treatments. While Martinson and 

Omi (2003) reported that fuel treatments of various types reduced crown fire in eight large events, more 

recent research (Strom 2005, Stephens et al. 2009) has shown that mechanical thinning fuel treatments are 

not nearly as effective in decreasing fire intensity and spread as the combination of thinning and prescribed 

fire in western United States forests. Strom noted that, ―prescribed burning without cutting was associated 

with reduced burn severity, but the combination of cutting and prescribed burning had the greatest 

ameliorative effect.‖ (Strom 2005, p. ii).

Stephens et al. (2009) shows the importance of using prescribed fire after mechanical treatments in order to 

increase the treatment effectiveness of reducing potential fire severity under severe weather conditions. 

See Response at LCEC-5.

The Forest Service would consider contracts for removal of small diameter trees or slash if markets support 

these contracts (FEIS pg. 2-5, 2-8). There are some portions of the project area where market conditions 

(even though the project area is within 50 miles of a fuels for schools waste wood boiler, and within 200 

miles of a paperboard facility) may prevent utilization of all slashed material. In these areas, pile and/or 

broadcast burning would be needed to address the purpose and need while meeting Montana slash 

treatment standards (MT Dept. of Natural Resources and Conservation Rule 36.11.222 and 36.11.223).

Martinson, E.J., Omi, P.N., 2003. Performance of fuel treatments subjected to wildfires, in: Omi, 

P.N., Joyce, L.A. (Eds.), Proceeding Conference on Fire, Fuel Treatments, and Ecological 

Restoration. Proc. RMRS-P-29. U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Research Station, Fort Collins, CO. pg.. 7–13. 

Stephens, S.L., J.L. Moghaddas, C. Edminster, C.E. Fiedler, S. Haase, M. Harrington, J.E. Keeley, 

E.E. Knapp,7 J.D. Mciver,K.Metlen, C.N.Skinner, and A.Youngblood. 2009. Fire treatment effects 

on vegetation structure, fuels, and potential fire severity in western U.S. forests, Ecological 

Applications 19(2) (2009), pg. 305-320. 
Response to Comments

Lower West Fork Project Final EIS 4-5

Strom, B. 2005. Pre-fire treatment effects and post-fire forest dynamics on the Rodeo-Chediski 

burn area, Arizona. M.S. thesis, School of Forestry, Northern Arizona University, Flagstaff. In: 

Pollet, J. and P.N. Omi. 2002. Effect of thinning and prescribed burning on crown fire severity in 

ponderosa pine forests, International Journal of Wildland Fire 11 (2002), pg.. 1–10.

https://library.eri.nau.edu:8443/bitstream/2019/252/1/Strom.2005.PreFireTreatmentEffectsAnd.pdf

BA-1: This trail (Piquett Cr. Rd. 49, beyond the closure gate) could be considered for over 50" width 

OHV's, since it is already wide enough for 2 highway vehicles to pass one another.

Alternative 2 does not appreciably degrade the quality of the ride or the length of it. 

While #3 does not appreciably affect BA's currently permitted routes, it does permanently eliminate 

some possibilities of looping routes together in the future.

This analysis uses the current definition for motorized use. The travel management analysis currently in 

process is the arena for considering different definitions or classes of OHVs. The roads past the closure 

gate on NFSR 49 are proposed as open seasonally to vehicles 50‖ or less in the travel planning project

Alternative 1. 

Road management is the same in Alternatives 2 and 3 in the Castle Creek drainage, beyond the gate on 

NFSR 49. The same roads are proposed for decommissioning or storage. The only road management that 

would permanently eliminate road use possibilities would be the decommissioning of NFSR 74607. Roads 

that are stored can be re-opened if needed for future management or administration. If a future NEPA 

decision determines NFSR 74606 needs to be extended to create a loop, the road would be re-opened.

BA-2: ...hope is that there could be a loop created--enough to make the ride a little longer. 

Near the upper end of Road 74606 is a posted (closed) trail that could be considered for a Loop.... 

The feeling is that it could be joined with Trail #49 to created approximately a 5 mile loop.

NFSR 74606 is slated for storage. This road is currently operated as a trail, meaning it is closed to full size 

vehicles yearlong, and open to ATVs or motorcycles seasonally, 12/02 to 10/14. During public 

involvement for the Lower West Fork project, the Forest Service presented this road to the public as 

changing from its current designation to closed yearlong to all motorized vehicles; essentially, it would be

placed into long term storage. This road, as it is currently constructed, would be available for future use 

but would require NEPA analysis for any additional construction needed to create a loop. This decision 

does not prevent that potential use. 

BA-3: support closures of roads that contribute to stream degradation.

FR 74606, located in Castle Creek, is listed in both Alternative 2 and 3 for storage (FEIS pg. 2-31, 2-35, 

3.6-23, 3.6-31). This road is included in both alternatives because compaction of the road surface is 

reducing runoff infiltration and retarding vegetation recovery, is in an area that burned in 2007, has high 

road densities, and is not needed for forest management in the near future. Although there may be no 

visible sediment trails from the road to streams, compaction of the road surface increases and concentrates 

runoff, increases erosion (on and off the road surface), and reduces vegetation growth. See also the 

response to comment LTPM-6 below.

BA-4: ...I do not believe wildlife is impacted by the roads or the travel on those roads.

The purpose of proposing roads for storage or decommissioning in this analysis was to reduce 

sedimentation and improve fish passage by reducing road densities and the number of road-stream 

crossings (FEIS 2-5, 2-12, 2-15). Additional road closures were analyzed in the FEIS to meet or improve 

Elk Habitat Effectiveness (EHE) in the six watersheds that do not meet the EHE. (FEIS pgs 3.8-15, 3.8-16,

3.8-20, 3.8-21). Scientific studies have documented the effects of roads on wildlife since 1976 (Gruell and 

Roby 1976). Subsequent research has refined the initial correlations with volume of traffic, types of use, 

and other factors (Papouchis et al. 2001, Mace et al. 1996, Naylor et al. 2009).
Response to Comments

Lower West Fork Project Final EIS 4-6

LTPM-1: timber... the chief component of the homes of most of us and a product which continues to 

grow and support the Montana economy.

The Forest Service recognizes the importance of wood and paper products to Missoula and Ravalli 

counties, as well as the state, regional and national economies (FEIS 3.13-4). This project would contribute

wood products from national forest system lands to the local economic impact area.

LTPM-2: I believe today we have a much better understanding of land treatments and methods of 

harvest than were practiced in the 60's thru the 90's. The forests can be harvested and still remain a 

national treasure that we can be proud to own.

The proposed project is suitable and appropriate for timber harvest (FEIS pg. 3.2-4)

LTPM-3: Great improvement in machinery no longer require nearly the road systems as before...

I believe the gate system is less costly and in fact these roads have already been bought and paid for

...

It is true that changes in machinery have changed transportation system needs. Roads proposed for storage 

or decommissioning often have open roads nearby that provide motorized access to within a few hundred 

feet of the stored or decommissioned road. Roads no longer needed for management of timber or other 

resources are proposed for decommissioning. Roads needed for future timber management but not for 

current resource management are proposed for storage. Decommissioning roads no longer needed for 

current or future resource management decreases long-term sediment production (FEIS 3.6-8, 3.6-18, 3.6-

19). The Montana Department of Environmental Quality lists the West Fork of the Bitterroot River as 

Total Maximum Daily Load impaired. Properly storing and decommissioning roads reduces non-market 

costs (damage to water quality and fisheries) by reducing sedimentation from roads. Decommissioned 

roads no longer require periodic maintenance, which reduces the overall cost of managing the Forest 

Service road system. In addition, the gate system is not always effective in managing motorized vehicle

use. People damage or drive around gates, and disregard the posted regulations. Law enforcement and the 

repair of gates and signs, are costs incurred when managing gated road systems that are not incurred when 

roads are decommissioned. See also, the response to BA-3, above.

LTPM-4: I do continue to object however to the areas on the maps slated for road decommissioning. 

In some cases these roads provide a secondary escape route in the event of fire for crews. ...You 

must remember the reintroduction of fire will be an ongoing event and still remains a danger if the 

area is cut off from reasonable management methods.

All of the roads proposed for decommissioning are ends of road segments. These roads would not be used 

as a secondary escape route because they do not lead out to any other roads. The Forest Service does not 

compromise firefighter safety by decommissioning these roads. If an escape route is not available,

firefighters will not engage the fire until one becomes available. In some instances, firefighters may have a 

longer hike into a fire because a road was decommissioned. During the reintroduction of fire, an analysis 

of fuel moistures and weather conditions will be conducted before deciding to manage an unplanned 

ignition for resource benefit. The road network remaining after Lower West Fork project implementation 

will be adequate to provide fire managers multiple options when looking at reintroducing fire to the 

landscape.

LTPM-5: Also in some cases these road provide hunting opportunities into areas that are used.

Restoring fire to the landscape and improving soil, watershed, and fishery conditions were the purpose and 

need for the Lower West Fork project. Improving soil, watershed, and fisheries conditions were the driving 

factors when proposing roads for storage or decommissioning in this analysis (FEIS 2-3 thru 2-4, 2-8, 2-

15). Although 29 miles of roads would be either decommissioned or stored in Alternative 2 and 46 miles in 

Alternative 3, more than 50 miles of roads would remain open yearlong to all motorized users in the 

analysis area (FEIS 3.12-12). Most of the hunting use in the Lower West Fork analysis area is concentrated 
Response to Comments

Lower West Fork Project Final EIS 4-7

on the Piquett Creek drainage (FEIS 3.12-3) where road density is high and EHE is marginal. The roads 

remaining open will be adequate to provide hunting opportunities. 

LTPM-6: in most cases (roads) do not contribute to any great degree much silt into our streams. 

Our fish population can withstand much more silt than we are led to believe. 

Fish have always had to live with sediment because sediment is a natural feature of all stream systems. The 

source (natural versus man-made), timing (constant versus pulsed), and quantity (low versus high) of the 

sediment makes a big difference to fish. Roads generally do not contribute large amounts of sediment to 

fish habitat on any given day; however, they are a permanent feature on the landscape and prone to erosion. 

Because they are permanent and erosive landscape features, roads erode, increase overland runoff, and add 

sediment to streams above the natural sediment load of the watershed any time a rain storm occurs. 

Therefore, more sediment enters fish habitat than would naturally occur in an unroaded watershed; this 

sediment builds up over the years and degrades fish habitat (Furniss et al. 1991). The point is that roads 

continue to contribute elevated (above natural levels) amounts of sediment as long as they are present on 

the landscape. This is known as a ―press disturbance‖ because the disturbance is chronic and maintains fish 

habitat in a less than desired condition as long as the roads are present (Reeves et al. 1995). Burned hill 

slopes, by contrast, generate a very high pulse of sediment for 2-3 years, but erosion rates typically decline 

to pre-fire conditions within 5 years (Elliot and Robichaud, 2001). This is a ―pulse disturbance.‖ Fish 

withstand pulse disturbances better than press disturbances (Reeves et al. 1995). Finally, the Fisheries 

Biologist does not know of any scientific literature that supports the assertion that roads are beneficial to 

fish habitat. At best, they can be built in benign locations (e.g. ridges, upland slopes with no stream 

crossings) and have a neutral effect on fish habitat. The vast majority of the scientific literature clearly 

shows that roads have a negative effect on fish habitat. Furniss et al. (1991) provides a good summary of 

road sediment research and lists numerous studies and authors.

LTPM-7: I support as you know any and all forest management efforts using our new 

understanding of forest needs and the prevention of stand replacement fires

The Forest Service appreciates your support. As you are aware, forest management embodies not only the 

trees of the forest but the other vegetation and fauna that inhabit the particular forest ecosystem, and the 

streams and soils that support them. This analysis applies current science to evaluate forest resource 

conditions (FEIS 3.6-4 through 3.6-7, 3.7-10), estimate environmental effects (FEIS 3.6-16 –3.6-21, 3.6-29, 

3.7-10 –3.7-20, 3.7-29) and provide forest management recommendations (FEIS 2-17, 2-18, 3.6-38 – 3.6-

40).

CT-1: I have very serious concerns, however, that neither the preferred alternative nor either of the 

other alternatives fully analyzed in the DEIS will achieve these stated goals.... I have provided 

comments and a silvicultural prescription which will achieve the desired results. 

How the alternatives achieve the purpose and need are summarized in the FEIS on pages 2-5, 2-12, 2-15, 

and 2-16, respectively, and described in more detail on pages 3.2-26 – 3.2-32. Thinning from below to a 

stand density determined by site capability and selecting to leave shade-intolerant tree species would 

reduce fuels, leave the larger trees on the site, and increase the distance between tree crowns. Removing 

small trees in the understory raises the base canopy height of the stand and prevents surface fire from 

moving into the tree crowns. The larger, shade-intolerant tree species that make up the stand following 

treatment have had more time to develop fire-resistant bark and withstand insect attacks or disease 

infections. Increasing the spacing between tree crowns, provides more growing space for the remaining 

trees to improve their vigor and put more energy into developing their defense mechanisms (FEIS pg. 3.2-

26—31).

CT-2: I request that the FS analyze my silvicutural prescription as a separate, proposed alternative 

or, failing that, the FS incorporate my harvest prescription and as many of my comments as possible 

into the alternative that is ultimately selected by the FS.
Response to Comments

Lower West Fork Project Final EIS 4-8

There is no need to analyze this prescription as a separate alternative. This prescription is incorporated in 

both Alternatives 2 and 3 on appropriate sites (FEIS pg. 3.2-18—3.2-20). The harvest prescriptions are

also incorporated as allowed by law and regulation (FEIS pg. 2-8 –2-10, 2-15 – 2-17, A-4–A-7).

CT-3: ...the USFS will need to prioritize all mitigation factors in a descending order of importance.

Mitigation measures are mandatory, design features of the project. Their application is not optional, 

therefore, they do not need to be prioritized. Rehabilitation projects not directly associated with timber 

harvest but included in this analysis are optional and their priority is based on funding sources beyond the 

current timber sale. For example, the mitigation measure to reduce soil erosion, and prevent stream 

sedimentation and noxious weed spread in timber harvest units requires the timber sale administrator to 

evaluate disturbed sites and consult with the resource specialists to determine the erosion control and 

revegetation needs. The practices that could be applied, as dictated by the needs of the site, include 

recontouring, shallow ripping, seeding, fertilizing, shrub planting, and covering the soil with mulch or slash 

(FEIS pg 2-18). These practices would be accomplished as part of the timber sale.

Rehabilitating historic skid trails in Unit 2 that would not be used as part of this project is an example of a 

project that would not be ―mandatory‖ and would require appropriated funds or other funding sources for it 

to occur. However, because the ID Team analyzed the effects of sub soiling these trails in this analysis, the 

project would not need additional NEPA analysis for it to proceed.

CT-4: Reduce the BAF to 40-80 (10 foot between crowns absolute minimum crown closure) in a 

varied mosaic including the removal of large and small trees favoring retention of the larger, healthy 

trees. All treatment methods that meet the Purpose and Need and that can be safely operated, as is 

normal industry practice, shall be allowed (see Mimicking Nature‟s Fire by Arno and Fielder). 

Ground based systems should be preferred. Care shall be taken to remove as many of the limbs and 

needles as possible to reduce the fuel loading. Areas may be clumped, thereby creating openings that 

break the fuel continuity. Specifically, large PP that have overlapping canopies may be retained in 

groups with no skidding under those crowns. Openings shall be created next to such clumps to 

average the BAF for the area. 

The silvicultural prescription you described is appropriate in mature ponderosa pine dominated stands and 

will be implemented with minor variations under Alternatives 2 and 3 (FEIS pg. 2-8, 2-9, 2-13). In other 

stand types with different historical fire regimes or in younger stands, different prescriptions are warranted

(Arno and Fielder 2005). The prescriptions and harvest methods are designed to balance resource 

management needs with efficient timber harvest and applicable laws and regulations.

Some limbs and needles are necessary to leave on the ground for nutrient cycling. The ID Team expects

that needles, branches, and tops will break out of trees during harvest. This material will be left in the 

treatment units as needed for nutrient cycling and the prescribed fire treatment. Refer to the discussion on 

nutrient cycling in the FEIS pages 3.5 -13 – 3.5-14. 

CT-5: All trees with two or more bug hits shall be removed as biomass.

Trees with bark beetle attacks around 2/3 circumference would be removed. Verification of attacks would 

be based on frass at the base of trees or in bark crevices (Hagle, S.K., K.E. Gibson, and S. Tunnock 2003). 

Presence of successful pitch tubes would be another indicator. 

Unhealthy, excess trees will be marked for removal first. Whether they are removed as wood products 

depends on economic and technical feasibility. In general trees greater than 6.5‖ dbh qualify for removal as 

wood products. 

CT-6: All chimneys that adjoin the private must have at least two breaks in the fuel continuity.

Within the Lower West Fork project, there are no chimneys located below private land so fire would not be

funneled uphill towards people or private land values. There are areas within drainage bottoms that adjoin 

private land that will be left untreated by mechanical means because they are Riparian Habitat 
Response to Comments

Lower West Fork Project Final EIS 4-9

Conservation Areas (RHCAs). The fisheries mitigation measures (FEIS pg. 2-19 –2-21) describe the 

management limitations within RHCAs. The proposed action addresses reducing the potential fire 

behavior within these areas by allowing small tree thinning to within 50 feet of streams and the use of hand 

ignited prescribed fire within RHCAs.

CT-7: Snags shall be retained at a density of 1.5-3 per acre average or less.

All snags that do not present an Occupational Safety and Health Administration (OSHA) hazard would be 

left on site.

CT-8: Alternate thickets of small trees shall be retained and removed as necessary to meet the BAF 

specifications while also providing habitat for smaller wildlife. Particular care should be used to 

avoid the corn field effect.

This silvicultural prescription is appropriate in even-aged ponderosa pine stands when regenerating a 

portion of the stand is desirable. This prescription creates younger cohorts and moves the stand closer to an 

un-even aged structure (Arno and Fielder 2005). This prescription, with the addition of prescribed fire, is 

proposed in appropriate stands under Alternatives 2 (FEIS pg. 2-8, 2-9) and 3 (FEIS pg. 2-13).

CT-9: ...care shall be taken to avoid impact or damage to retained trees during the reintroduction of 

fire.

The reintroduction of fire will be conducted under such conditions that tree mortality is within the limits set 

by the silvicultural prescription (FEIS pg. 2-10, 3.2-28). In some units prescribed fire may be used to 

recruit snags and create coarse woody debris. Various techniques may be used to protect residual trees 

such as ignition patterns and timing, and pulling slash and raking duff from the base of trees.

CT-10: Additionally, no large brush piles or concentrations shall remain on the treatment area at 

the conclusion of the treatment.

Landing piles would be removed through utilization or by prescribed fire when conditions make it safe and 

effective to do so. This means that piles may remain 1-5 years following harvest. Slash piles on the 

Frazier Interface Timber Sale were burned within three years of the sale closure and slash piles on the 

Middle East Fork HFRA project are burned when the units close. 

CT-11: All ground based off-road operators shall complete a soil moisture test on a daily basis or 

anytime varying soil moisture conditions exist.

Prior to the start of logging operations, timber sale administrators assess soil moisture conditions. Ground 

skidding can take place when soil moisture is at or below the permanent wilting point. Vegetation 

characteristics can be used to determine if soil moisture is near the permanent wilting point. Vegetation 

should have little active growth and will be nearly senesced. If visual observations of vegetation do not 

provide enough information, the soils can be assessed directly by grabbing a handful of soil and squeezing 

it in the palm. Dry soils should crumble or deform when the palm is opened. Soils that retain shape after 

squeezing contain enough moisture to increase the ability of the soil to become compacted. Refer to the 

soil mitigation practices for ground-based yarding (FEIS pg. 2-18 –2-19), which are discussed on pages 

3.5-14 through 3-17 and 3.5-25.

CT-12: THE VEGETATIVE PRESCRIPTION SHALL ALSO BE APPLIED IN THE RIPARIAN 

AREAS.... conifers,...must be removed to restore the natural function of the stream and its 

vegetation. The USFS shall follow the Montana BMPs to accomplish this. Aspen restoration must be 

a priority as well as beaver reintroduction neither of which are emphasized in the DEIS. The USFS 

shall follow the Montana BMPs

Applying the vegetative prescription in riparian areas in the Lower West Fork project area would violate 

the Forest Plan. The Forest Plan, as amended by INFISH, prohibits timber harvest in Riparian Habitat 

Conservation Areas (RHCAs) with two exceptions: 
Response to Comments

Lower West Fork Project Final EIS 4-10

(1) where catastrophic events such as fire, floods, volcanic, wind or insect damage result in 

degraded riparian conditions and present and future woody debris needs are already being met; or 

(2) where vegetative treatments are needed to attain the Riparian Management Objectives (i.e. 

pools, large wood, cold water temperatures, and narrow stream channels). 

Clearly, exception (1) does not apply to the Lower West Fork project. As for exception (2), timber harvest 

in RHCAs would not increase pool habitat, increase large wood recruitment into streams, decrease water 

temperatures, and narrow stream channels in the Lower West Fork project area. In the spruce/fir riparian 

areas that dominate the Lower West Fork project area, removal of timber is likely to do the opposite, 

resulting in fewer pools, less large wood, less shade, and less stable stream channels. For that reason, 

removing timber from the riparian areas would violate the Forest Plan and BMPs (FEIS pg. A-4 –A-8).

While the Bitterroot NF recognizes the need and importance of both aspen restoration and beaver 

reintroduction, the purpose and need of this project does not focus on these objectives. For the most part, 

the stream habitat that is present on National Forest land in the Lower West Fork analysis area is not 

suitable for beaver because most of the streams are steep and have high gradients with narrow riparian 

corridors and floodplains. Beaver prefer low gradient, meandering streams that contain wide floodplains 

dominated by deciduous shrubs. In the Lower West Fork project area, suitable beaver habitat is generally 

restricted to private lands along and near the West Fork Bitterroot River. 

Prior to the fires of 2000, which burned over 307,000 acres of the Bitterroot NF, the decline of aspen 

stands was a concern. After those fires, the Forest Service observed the healthy regeneration and expansion 

of aspen clones. Based on these observations, the ID Team believes the proposed prescribed fire treatments 

will continue to restore healthy aspen stand without special emphasis.

Beaver populations appear to be stable and colonizing available habitat. This trend will likely continue as

tolerated by private land owners. Maintaining intact riparian areas will promote beaver dispersal.

CT-13: ...it is absolutely necessary to prescribe a method for checking the silvicultural prescription 

during and after the project to determine whether the objective has been met. Specific methods must 

be written into the final EIS to insure that the silvicultural prescription is met.

Silviculturists supervise the marking on harvest units and monitor the harvest in the units, especially when 

special circumstances exist in the unit. They document prescription results with post-harvest exams and 

maintain the results in project files. 

Specific methods for monitoring the implementation of the silvicultural prescription do not need to be 

written in the FEIS because they are administrative functions and would not differ between alternatives. 

There are many checks on the implementation of the silvicultural prescription through administration of the 

marking and timber sale contracts, and Forest Plan monitoring at the completion of the sale

CT-14: ...there is not a meaningful difference between the two alternatives that were analyzed with 

respect to the key issues I have set forth above in my comments....By failing to fully assess a range of 

reasonable alternatives, the FS has avoided its obligations under NEPA to take a hard look at the 

environmental consequences of its actions

The three alternatives analyzed in the FEIS provide a reasonable range of alternatives that addressed the 

issues brought up during public scoping and meet the purpose and need of the Lower West Fork analysis

area (FEIS pg. 1-2, 1-4, 2-4). Alternative 1 is the No Action alternative and provides a benchmark that 

enables decision makers to compare the magnitude of environmental effects. Alternative 2 was the 

proposed action the Forest Service developed to address resource concerns in the project area. Alternative 

3 was developed from public comments the Forest Service received through scoping (FEIS pg. 2-12, 2-15). 

Commercial harvest and prescribed fire use would not occur east of the West Fork River because some 

people felt that the fires of 2000 and 2007 had reduced fuel loads in this area. Alternative 3 was analyzed 
Response to Comments

Lower West Fork Project Final EIS 4-11

because it addressed the purpose and need and would display the effects of no timber harvest on the east 

side of the West Fork River on community fire protection.

Several alternatives were considered but not analyzed in detail because they were already part of 

Alternatives 2 or 3, or they did not address the purpose and need for the project (FEIS pg. 2-16, 2-17).

CT-15: I urge the Forest Service to incorporate as many of my comments as possible into the 

alternative that is ultimately selected so that the alternative complies with the FS obligations under 

the law and fully explain why any comment that was not included has been rejected by the FS.

The alternatives analyzed in this project incorporate public comments as described in the response above 

(CT-14) and in the FEIS pg. 2-3, 2-4). They are consistent with laws and Forest Service regulations (FEIS 

pg. 3.2-37, 3.3-21, 3.4-13, 3.5-34, 3.6-39 – 3.6-42, 3.7-32, 3.8-60 – 3.8-63, 3.9-11, 3.10-14, 3.10-15, 3.11-

5, 3.12-15, 3.13-9, 3.13-10).

SSC-1: Your proposal to address fuel loading, stand health and composition and the other issues 

within this landscape are worthy ones. It is good to see the Forest take a proactive stance in 

addressing these needs before catastrophic events such as fire and insect out breaks occur.... I 

recommend that this project be moved forward.

Thank you for your support. 

SSC-2: ...it addresses the real threat of wildland fires.... it will improve forest health by removing 

suppressed and diseased trees.... The FS has as a mandate to manage these lands and the activities 

proposed does just that. Other benefits from this project include improving transportation systems 

by addressing BMP‟s on existing roads and eliminating unnecessary roads. It will also improve 

wildlife habitat and water quality.

Lower West Fork Alternatives 2 and 3 reduce stand stocking by thinning from below and retaining the 

larger, seral trees as the dominant stand component (FEIS 2-8). Prescribed fire would be used to further 

reduce ground and ladder fuels in the commercially thinned stands as well as in units that do not require 

stand density reduction (FEIS pg. 2-9). Road improvements have also been included in the action 

alternatives (FEIS pg. 2-8, 2-12, 2-18, 3.6-21, 3.6-22, 3.6-30, 3.6-31). 

SSC-3: Smurfit-Stone can utilize these small trees as we can chip them up to use in our papermaking process. Additionally, there is the opportunity to grind the left over slash which can be 

burned in our boiler creating steam and electricity for our use.... it is important to provide material 

close to our mill which this project does.

Prior to the announcement of the mill closing, Smurtfit-Stone contacted the West Fork Ranger District to 

describe their interest in accessing chips and slash from the relatively proximate Lower West Fork project

(PF-PUB-INV-31). There will be small-diameter utilization opportunities associated with this project. 

However, due to terrain and road limitations, some areas will not support landings large enough to allow 

chip van access. If market conditions permit, some material in these areas may be mechanically handled 

more than once, allowing utilization above what is currently anticipated.

SSC-4: I would recommend including more ground based areas to help offset the higher cost skyline 

units.

Ground-based yarding is limited to slopes less than 40% to protect soil resources (Bitterroot NF Forest Plan 

FEIS pg IV-43, A-4). Treatment units were chosen that would meet the purpose and need of fuel reduction 

on a landscape basis (FEIS pg. 1-2). Ground-based area is 42 percent of the harvest area in Alternative 2 

(FEIS pg. 2-16) and 46 percent in Alternative 3 (FEIS pg. 2-16).

FOB/WWI-1: Alternative 1 (no action), with the addition of restoration activities that would remove 

manmade impediments to natural recovery, could approximate this approach. The road restoration 

and culvert work described in Alternative 3 addresses that issue better than that in Alternative 2.
Response to Comments

Lower West Fork Project Final EIS 4-12

The Alternatives present a range of activities from which the decision maker can review and select. The 

range of activities chosen in the Record of Decision may contain a mix of activities presented and analyzed 

in the DEIS (40CFR 1505.1(e)). For example, the Deciding Officer may choose Alternative 1 but decide to 

include the road and culvert work analyzed under Alternative 3 because the effects of both activities are 

disclosed in the analysis. And, their combined effects would be within or less than the range of effects 

described in the EIS. 

An alternative that included road and culvert work but no vegetation treatment was considered but not 

analyzed in detail. Because road and culvert work is analyzed in Alternatives 2 and 3 (FEIS pg. 2-8, 2-12)

and no vegetation treatment is analyzed in Alternative 1, another alternative analyzing their separate effects 

was not needed. An alternative that considered no vegetation treatment would not address the need to 

reduce fuel loads, improve the resilience of large diameter ponderosa pine, or maintain or improve the 

representation of shade-intolerant species in the stand (FEIS pg. 1-2, 2-15).

FOB/WWI-2: We fully support the proposed watershed restoration activities and believe much more 

is required in many areas to allow future logging to occur within legal limitations.

Thank you for your support regarding watershed restoration. The Water Quality Restoration Plan and Total 

Maximum Daily Loads for the Bitterroot Headwaters Planning Area, ―Restoration Plan‖ (Montana 

Department of Environmental Quality 2005) lists the West Fork River as impaired because of siltation and 

temperature modification (FEIS pg. 1-4, 3.6-1, 3.6-2, 3.6-4, 3.7-6, 3.7-9, 3.7-10). The Restoration Plan 

recommends that sediment from roads be reduced (FEIS pg. 1-4, 3.6-1, 3.6-2). None of the tributaries to

the lower West Fork River are listed as 303(d) impaired within the project area. The timber harvest 

proposed in this analysis is within legal requirements (FEIS pg. 3.6-39 thru 43). The ID Team, 

representing soils, watershed, fisheries, silviculture, fire, recreation, wildlife, travel planning, and logging 

systems, evaluated each road and cooperatively developed the restoration activities in Alternatives 2 and 3 

based on resources at risk, future transportation needs, as well as past, present, and future resource needs

(PF-WAT-36). 

Through proper application of roads and trails and timber harvest BMPs (FEIS Appendix A), sedimentation 

from the proposed timber harvest would be negligible (FEIS pg. 3.6-20, 3.6-21, 3.6-29, 3.6-30, 3.7-13 –

3.7-21, 3.7-30). Mandatory stewardship activities as discussed in the FEIS are those activities included in 

the stewardship contract and funded by the timber sale. Other stewardship activities analyzed in the FEIS 

are not directly tied to timber harvest but are connected to the analysis and would be completed as funding 

becomes available. The mandatory stewardship activities listed in the FEIS and hydrology specialist report 

(FEIS pgs.PF-WAT-31 pg. 3.3-28, 3.3-36, and 3-37) would decommission or store nine roads (11.6 miles) 

and remove 15 culverts in Alternative 2. These actions would reduce annual sediment yields by an 

estimated 18.7 tons/year. Under Alternative 3, mandatory stewardship activities would decommission or 

store 11.8 miles of road and remove 18 culverts, which would reduce annual sediment yields by 

approximately 20.4 tons/year. The ID Team identified the mandatory restoration opportunities that would 

provide the greatest benefit to aquatic resources. They also selected the projects that could be 

accomplished within the period of the stewardship contract, or earlier with appropriated or partnership 

funds. The implementation of these restoration activities would offset any potential sediment inputs 

resulting from fuel management activities, reduce long-term sediment inputs, and improve water quality in 

the Lower West Fork analysis area as recommended in the Restoration Plan (See also FOB/WWI-28). 

For hydrologic units in the Lower West Fork analysis area, there would be a reduction in the number of 

culverts, sediment contributing points, from the implementation of the mandatory items as well as the entire 

improvement package. The mandatory and complete improvement package would move the resource 

toward attaining the Restoration Plan recommendations. Table 1 displays the sediment reductions in the 

hydrologic units under Alternatives 2 and 3.

Table 1: Sediment Reduction in the Lower West Fork and Piquett Hydrologic Unit Codes (HUCs) in the 

Lower West Fork Analysis Area
Response to Comments

Lower West Fork Project Final EIS 4-13

Soil rehabilitation activities have been proposed in commercial thinning units to address past soil 

disturbances. Skid trails from previous timber harvest entries would be re-used in ground-based logging 

units to reduce new soil disturbance (FEIS pg. 2-18, 3.5-12, 3.5-16). Skid trails used to yard timber during

harvest would be decompacted by subsoiling (FEIS pg. 2-11, 2-18, 3.5-16, 3.5-18). Commercial thinning 

units that currently exceed the Region 1 Soil Quality Standards (R1 SQS) will have a net improvement in 

soil quality following thinning and soil rehabilitation treatments (FEIS 2-11, 2-25, 3.5-25). If other 

treatment areas are selected for future projects, past soil disturbances will be addressed to ensure R1 SQS 

are met.

FOB/WWI-3: We disagree with the rationale for the supposed need to remove fuel beyond the Home 

Ignition Zone (HIZ) or Community Protection Zone (CPZ) for the purpose of protecting human 

safety or private property.

The purpose of the Lower West Fork Project is to reduce fuel loads in and adjacent to the WUI and 

improve forest resilience to natural disturbance factors such as fire, insects, and disease (FEIS pg. 1-2, 1-4). 

One of the objectives is to lower crown fire hazard in low elevation ponderosa pine/Douglas-fir forests 

(FEIS pg. 1-2). Though the Forest Service recommends and encourages the removal of fuels within the 

Home Ignition Zone to reduce the probability a home would burn during a wildfire, that action is not 

enough to meet our purpose and need of lowering crown fire hazard and improving forest resilience in the 

Lower West Fork project area

In a recent issue of Forest Management and Ecology, Safford et al. found that ―with a few exceptions, fuel 

treatments substantially moderated fire severity and reduced tree mortality during the Angora Fire‖ 

(Safford 2009 pg. 14). Safford also stated, ―in most cases, crown fire was reduced to surface fire within 50 

m of the fuel treatment boundary; when combined with other considerations, we conclude that 400–500 m 

appear to be an absolute minimum width for most WUI fuel treatments‖ (Safford, 2009, p14). Treatments 

in the Lower West Fork project area extend about 1500 meters. 

Forest vegetation in the Lake Tahoe Basin (LTB), though different, has many similar characteristics to the 

vegetation in the Lower West Fork analysis area. The Angora Fire burned in the LTB WUI during June 

2007. Forest vegetation on 83 percent of the pre-fire area was Jeffrey pine (Pinus jeffreyi) and white fir 

(Abies concolor) at the lower elevations (Safford, 2009, p2). Jeffrey pine is similar to ponderosa pine 

because it is a shade intolerant, fire adapted species. White-fir is similar to Douglas-fir because it is shade

tolerant, regenerates in the understory, and is susceptible to fire-caused mortality. Safford (2009) states, 

―Pre-settlement fire return intervals in the LTB probably averaged 5–20 years in Jeffrey pine-dominated 

forests (Stephens 2001,Taylor and Beaty 2005). As in much of the Sierra Nevada, active fire exclusion in 

the LTB has nearly eliminated fire as a natural ecological process. In addition, a large proportion of the 

Lake Tahoe Basin (including much of the Angora Fire area) was heavily logged in the late 19th and early 

Alternative 2 Alternative 3

Lower West 

Fork HUC Piquett HUC Lower West Fork HUC Piquett HUC

Existing estimated sediment from 

culverts (1.7 tons/culvert) 190 tons/year 165 tons/year 190 tons/year 165 tons/year

Total Reduction of annual 

Sediment contributions

15 tons 

(8% decrease)

12 tons 

(7% decrease)

15 tons 

(8% decrease)

24 tons 

(15% decrease)

Annual reduction of sediment 

contributions from mandatory 

stewardship activities

10 tons

(5% decrease)

9 tons 

(6% decrease)

10 tons 

(5% decrease)

10 tons 

(6% decrease
Response to Comments

Lower West Fork Project Final EIS 4-14

20th centuries. Together these factors have increased stand density, canopy cover, and surface fuels

(Murphy and Knopp 2000; Taylor 2004).‖ 

Safford, H.D., et al., 2009. Effects of fuel treatments on fire severity in an area of wildland–urban 

interface, Angora Fire, Lake Tahoe Basin, California. Forest Ecol. Manage. (2009), 

doi:10.1016/j.foreco.2009.05.024

FOB/WWI-4: ...perhaps NEPA analysis should be given to forest-wide amendments to the Forest 

Plan regarding these standards. That analysis would provide a larger scale, more comprehensive and 

updated assessment of the various situations not available with the piecemeal approach now being 

used.

The 1987 Forest Plan specifically allows for site-specific amendments ―If, during Forest Plan 

implementation, it is determined that the best way to achieve the prescription for a management area does 

not totally conform to a management prescription standard, the Forest Supervisor may amend that standard 

for a specific project.‖ (p. IV-5).

Appendix F, Forest Plan Amendment, analyzes the direct, indirect, and cumulative effects of the 

amendment, and the assessment of whether or not it is significant.

FOB/WWI-5: We would like to see protection of all large standing snags.

No snags would be cut in treatment units unless they are designated ―danger‖ trees. Snags designated as 

―danger trees‖ within treatment units are managed according to Occupational Safety and Health 

Administration (OSHA) regulations (29CFR 1910.266(h)(1)(vi) and (vii)). 

FOB/WWI-6: Winter Range Thermal Cover standard... is totally elastic, designed, a priori, to fit 

any desired timber removal. As such, it appears to be arbitrary regarding protecting elk.... this 

standard should be evaluated in light of protecting elk security from wolves.

There is an inherent conflict between the thermal cover standard on winter range in the Forest Plan and the 

need to restore high frequency, low severity fire regimes on winter range. Historic forest stand structures in 

winter range were typically open-grown ponderosa pine and Douglas-fir/ponderosa pine stands (FEIS pg.

3.8-21). Winter range thermal cover is defined as ―a stand of coniferous trees 40 feet or taller with an

average crown closure of 70 percent or more (Forest Plan 1987). Most of the habitats that make up winter 

range on the Bitterroot NF are incapable of producing or sustaining the canopy closures that provide 

thermal cover (FEIS pg. 3.8-14, 3.8-20, 3.8-24). Reducing stand densities to 80 ft2of basal area or less 

would reduce canopy closure below 70 percent. In order to address this, a site-specific amendment to the 

Forest Plan concerning winter range thermal cover must be adaptive and maintain cover on Lower West 

Fork treatment units but allow the removal of ladder fuels and excess stocking that predispose the units to 

crown fire. To clarify the intent of the Forest Plan amendment, the ID Team revised it to read, ―Thermal 

cover on winter range will be treated in the Lower West Fork analysis area to the extent needed to protect 

the overstory from loss due to fire.‖ (FEIS pg. 1-11)

Cook and others (1998) have researched the role thermal cover plays in the winter survival of elk, and

question the necessity of managing forests in order to provide such habitat. Thermal cover is apparently 

not as necessary for individual elk survival or elk population viability. Though this project would thin the 

overstory, it would not remove it entirely and some site protection would remain. However, the remaining 

site protection may not fit the definition of winter range thermal cover. The loss of up to five percent 

winter range thermal cover would not likely have a measurable effect on the elk population in the Lower 

West Fork or the Bitterroot Valley (FEIS 1-11, 3.8-14, 15, 21, 24-25).

Winter range thermal cover is not designed nor could it be designed to protect elk from wolf predation or 

pressure. Thermal cover is a habitat feature related to vegetation structure that modifies the effects of 

weather (Toweill and Thomas 2002). Thermal cover is largely a function of canopy closure and focuses on 
Response to Comments

Lower West Fork Project Final EIS 4-15

protecting the elk from snow in the winter and sun in the summer, wolf predation would not be affected by 

this feature. 

FOB/WWI-7: Given that the EHE standard regarding road density (security from human hunters) 

is not being met and can not be met in parts of the project area according to DEIS p.1-12, it would 

seem especially important to allow for more security from wolves, by leaving “thermal cover” where 

it exists, especially near meadows, within the project area.

Elk habitat effectiveness (EHE) is a measure of elk habitat use based on consistent evidence that elk do not 

fully use habitat adjacent to roads though habitat is available (Lyon 1983). Elk security is a measure of elk 

vulnerability during the hunting season and its purpose is to provide a reasonable level of bull survival 

(Hillis et al. 1991). EHE presumes an elk behavioral response conditioned by vehicular traffic on forest 

roads (Lyon 1983). Hiding cover may mitigate the negative response elk have to roads but effective road 

closures may be the best method for elk attaining full use of the habitat. Seasonal road closures contribute 

to elk security because they limit vehicular, and thereby hunter, access. 

The Wildlife Biologist reviewed the EHE analysis in the FEIS to ensure our assumptions complied with 

Forest Plan direction. The Forest Plan directs that EHE of 50 percent or higher (Lyon 1983) be maintained 

in currently roaded third order drainages (Forest Plan pg. II-21). The year-round closure of NFSR 5630 

would bring the Lavene drainage into EHE compliance. However, this road is open only during the 

summer when elk habitat is at a premium and people use the road for wood gathering and berry picking.

The main road in the Violet-Applebury drainages, NFSR 5720, accesses the Rombo Ridge Trailhead. The 

other roads are closed to all vehicles during the hunting season. Under alternatives 2 and 3, 02e424-2 

(Baker Creek) meets the EHE standard; EHE improves in 02e424-1 (Lavene Creek) and 02f427-3 (Wheeler 

Creek), and remains the same in 02h449-2 (East Piquett), 02h450-2 (East Main Piquett), and 02i450-1 

(Violet Creek) (FEIS pg. 3.8-16). Over the whole Lower West Fork analysis area, year-round open road 

densities would decrease to 2.2 miles per square mile in Alternative 2 and 2.0 miles/square mile in 

Alternative 3 (FEIS pg 3.8-26). During the hunting season, road density drops from 1.4 miles per square 

mile (Alternative 1) to 1.2 miles per square mile in Alternative 2 and 1.0 mile per square mile in 

Alternative 3 (FEIS pg 3.8-26).

Fifty-three percent of the Lower West Fork analysis area provides elk security habitat, which is more than 

adequate according to Hillis and others (1991). Cover in general is a factor in elk security but it can be 

hiding or thermal cover. Thermal cover and hiding cover are different concepts in elk habitat management 

(Ormiston 1978) and the focus of hiding cover is protecting elk from human hunters not wolves (Toweill 

and Thomas 2002). Thermal cover as defined above in FOB/WWI-6 would not affect wolf predation. The 

Lower West Fork project proposes to thin stands, which would leave forest canopy in the treated units 

though not enough in some areas to qualify as thermal cover. The intention of the treatments is to reduce 

the potential loss of cover from fire (FEIS 1-5–1-7). The fires in 2000, the Rombo fire, and the Douglas-fir 

beetle outbreak reduced cover on the Bitterroot NF. 

Wolf and elk have co-evolved and elk are capable of evading wolf predation. Forest canopies, though 

thinner, will remain intact following treatment. The forest will still intercept snow and reduce snow depths 

beneath the canopy. The habitat components that allow elk to evade wolf predation would remain intact 

following unit treatments. No treatment design would protect elk from predation by wolves. 

FOB/WWI-8: The FEIS must disclose the recently available spring 2009 elk count numbers, which 

show a significant decline from the 5,950 elk in 2008, which shows a significant decline from the 8,169 

elk in 2005. As the LWF DEIS admits (p.3.8-21), “No management activity can replace hiding cover 

in the immediate future”.

Spring elk counts for 2009 are disclosed in the FEIS (FEIS pg. 3-14). The elk count in the Bitterroot 

Valley is 6,166, which is an increase from the count in 2008 but a decrease from 2005. The elk population 

objective for the Bitterroot Valley, set by the State of Montana, is 6,200, ranging between 5,000 and 7,400 
Response to Comments

Lower West Fork Project Final EIS 4-16

animals based on the Spring count. Although elk numbers are decreasing in portions of the valley, the total 

number of elk meets the population objective; the population is less than record highs counted in 2003, 

2005, and 2006 but higher than historic numbers. During the record high years, elk hunting seasons were 

liberalized to bring populations to or below state objectives by 2009 as mandated by State Statute 87-1-323. 

The liberal hunting seasons along with growing predator populations have contributed to the decreasing elk 

population. 

The context of this comment implies that the elk population decline is related to low EHE, or lack of

thermal or hiding cover and that these habitat characteristics somehow tie to wolf predation of elk. As 

stated above, the elk population decline is most likely due to the liberal hunting season quotas intended to 

reduce population and meet state population objectives (Hamlin and Cunningham 2009). 

FOB/WWI-9: Lumping all wood 3 inches and larger into one category, CWD, does not distinguish 

the huge differences in fire behavior, soil building, moisture retention and wildlife values between a 3 

inch branch and a 30 inch log... Generally this failure to make important size distinctions leads to 

accumulating damage from loss of the more ecologically important larger logs and boles.

The discussion of coarse woody debris (FEIS pg. 3.5-13) identifies the value of coarse woody debris 

greater than 15 inches diameter and the need to leave it on site to the extent possible. The ID Team

recognizes that larger coarse woody debris is desirable to minimize fire behavior and promote long-term 

soil building and have included this recommendation in the mitigation measures (FEIS pg. 2-19). 

FOB/WWI-10: The FEIS should include analysis and disclosure of potential impacts of prescribed 

burning, especially in spring, to ground nesting birds or animals and impacts on plants, especially 

rare or sensitive plants. Spring burning goes against the rhythm of fire season and fire cycles that 

have shaped the forests and associated components over many thousands of years. It stands to reason 

that there are unforeseen and unintended consequences.

Fire exclusion allowed the build up of fuels and changed the components and character of the forests, 

which increased the intensity and severity of wildland fires (Graham et al. 2004). Fire exclusion has also 

changed the fire rhythms and cycles. Given the high fuel loads and the density of development adjacent to 

the forest, allowing unplanned ignitions to burn during the fire season without some prior reduction in fuel 

loads is not feasible (FEIS pg. 3.3-12).

The effects of prescribed fire on sensitive plants is included in the FEIS (FEIS pg. 3.10-10). Effects on 

land birds, including ground nesting birds are disclosed in the FEIS on pages 3.8 -57 and 3.8-58. While 

there may be impacts on individual animals and plants, the limited extent of annual prescribed fire use

would not cause any species declines. Saab et al. (2007) found that the influence of fire on both migratory 

and resident birds appeared to be short-term. Migratory bird response to prescribed fire was more variable, 

while resident birds generally had a positive or neutral response. Ground nesting birds typically favored 

burned habitats and had neutral responses to prescribed fire. There are areas with similar habitat conditions 

that would provide nesting or re-nesting habitats. Using prescribed fire as a tool to reduce fuels would 

ultimately allow some unplanned ignitions to burn more frequently during the typical fire season.

FOB/WWI-11: Proposed „temporary‟ roads need to be shown on a map in the FEIS.

Temporary roads and TLM trails are added to the Alternative maps. 

FOB/WWI-12: The effectiveness of R-1 SQS needs validation monitoring to see if it leads to 

protecting soil conditions that truly satisfy NFMA requirements.

To our knowledge, the R-1 SQS has never received public review and comment nor has it been peer 

reviewed. It seems to have been simply adopted by fiat. Please disclose substantiation by scientific 

reports.

...the USFS uses the surrogate measurement of Detrimental Soil Disturbance (DSD). The accuracy of 

the supposed linkage of this substitution has not been adequately evaluated or disclosed....That 
Response to Comments

Lower West Fork Project Final EIS 4-17

standard is totally inadequate; it throws the gate wide open. No amount of existing, logging-legacy, 

soil damage would preclude reentry for more logging.

The Bitterroot NF Plan adheres to the Regional soil quality guidelines to ensure soil resources are 

sustained. Soil properties including infiltration, water holding capacity, and filtering capabilities will be 

maintained if less than 15% of an activity area has been detrimentally disturbed. 

The Forest is bound by Forest Plan direction to ―plan and conduct land management activities so that 

reductions of soil productivity potentially caused by detrimental compaction, displacement, puddling, and 

severe burning are minimized‖ (BNF Forest Plan II.25 (7). This is being accomplished through project 

design and mitigation (FEIS pg. 2-11, 2-18, 2-19, 2-15, 3.5-11, 3.5-26 thru 3.5-28), and the implementation 

of BMP‘s (FEIS, Appendix A). Bitterroot NF Forest Plan II-25(8) also states ―Plan and conduct land 

management activities so that soil loss, accelerated surface erosion and mass wasting, caused by these 

activities, will not result in an unacceptable reduction in soil productivity and water quality.‖ Again, this is 

accomplished through project design, mitigations, and the implementation of BMP‘s. 

Powers et al. (2004) concludes that any standards await validation and will be updated as findings come in 

from research. Also, this issue is being reviewed at the national level with assistance from the research 

community (M Webster and D Page-Dumroese, personal communication). 

There is literature to substantiate using the soil quality standards as surrogates for soil productivity (PageDumroese et al. 2000; Meurisse 1987; Powers 1990; Cline and Ragus 1998). Powers (1990) (PF-SOIL030) cites that the rationale for the 15% limit of change in soil bulk density is largely based on collective 

judgment. The Forest Service estimates that a true productivity decline would need to be as great as 15% 

to detect change using current monitoring methods. Thus, the soil-quality (threshold) standards are set to 

detect a decline in potential productivity of at least 15%. This does not mean that the FS tolerates 

productivity declines of up to 15%, but merely that it recognizes problems with detection limits. Also, a 

15% increase in bulk density may not be detrimental to productivity; site and soil productivity depend on 

the soil and ecosystem in which it is found. 

The soil disturbance areal extent limit of 15% acknowledges that timber harvest and other land uses cause

some unavoidable impacts and impairment. This limit is based largely on what is physically possible, 

while achieving other resource management objectives. For example, 14 ft wide skid trails spaced 120 feet 

apart amounts to less than 10% disturbance. Conversely, uncontrolled skidding and machine piling can 

detrimentally impact 30% or more of the area. 

Application of the 15% areal limit has been debated. Bob Mueresse, a retired Region 6 Soil Scientist,

states, ―Applying the 15% areal limit for detrimental damage is not correct; it was never the intent of the 

15% limit and NFMA does not say that we can create up to 15% detrimental conditions. It says basically

that we cannot create significant or permanent impairment, period.‖ How that works out in terms of 

practicality is the problem; it may be more appropriate to look at the overall effect of an impact on an area. 

For example, displacement of several small patches of ground may not change site productivity, whereas 

displacement of one or two large areas may cause a substantial loss of site productivity. 

Detrimental soil damage is reversible in time if the processes (organic matter, moisture, top soil retention, 

soil organisms) are in place. Duration of effects is discussed (FEIS pg. 3.5-19). Rehabilitation techniques 

provide building blocks for soil productivity and speed the recovery process (FEIS pg. 3.5-23 thru 3.5-25). 

An exception to irreversible soil effects would be Forest Service system roads. System roads are 

considered permanent infrastructure and not part of the productive land base. However, roads can become 

part of the productive land base once they have been decommissioned.

FOB/WWI-13: The amount of increase in any degree beyond that is routinely not disclosed, nor is 

the depth of compaction disclosed. This information is necessary to determine the actual extent of 

damage and the degree of irreversibility. The information would also be necessary to design adequate 

mitigation and amelioration implementation.
Response to Comments

Lower West Fork Project Final EIS 4-18

Assessment of soil compaction from past harvest activities was completed using a shovel probe test. The 

Draft Northern Region Soil Monitoring Protocol (2008 pg. 25) describes the probe as an effective method 

to assess compaction in soils. No measurements of bulk density were collected to address actual amounts 

of increase in bulk density. Bulk density measurement is the only method that closely approximates the 

percent change in soil compaction over natural levels. Bulk density is a very time intensive and difficult 

sampling method to assess compaction. Also, bulk density sampling would not be feasible in units with 

elevated DSD levels because of the high number of samples required to account for site variation. 

Therefore, compaction is discussed in general terms and can vary from a 15% increase over natural levels 

to much higher levels. These compacted areas are found where past ground-based activities occurred 

(historic skid trails and roads). Many of the historic skid trails will be re-used during timber harvest and 

then subsoiled with the Subsoiling Grapple Rake (SGR) following treatment. The SGR breaks up 

compaction at depth with little to no mixing of soil horizons. 

Depth of compaction is disclosed (FEIS pg. 3.5-10, 3.5-28, 3.5-30, 3.5-35).

FOB/WWI-14: Discovery that an activity area has 15% or more detrimental soil damage should 

disqualify the area from further ground disturbing activities.

The Region 1 Soil Quality Standards state that ―In areas where more than 15% detrimental soil conditions 

exist from prior activities, the cumulative detrimental effects from project implementation and restoration 

should not exceed the conditions prior to the planned activity and should move toward a net improvement 

in soil quality.‖ See FSM 2500 – R-1 Supplement R1 2500-99-1.

FOB/WWI-15: The net effectiveness of mechanical de-compaction soil amelioration techniques 

needs to be analyzed and disclosed, as well as the degree of above mentioned ancillary impacts to the 

soil, (mixing mineral soil into top soil, aerating soil organic matter and thereby „burning‟ it up more 

quickly, spreading weeds, fragmenting mychorizae or otherwise disrupting the soil community).

The still experimental soil compaction amelioration techniques proposed are only partially effective 

and may in fact add to soil damage by way of mixing mineral soil into top soil, aerating soil organic 

matter (and thereby „burning‟ it up more quickly), spreading weeds, fragmenting mychorizae or 

otherwise disrupting the soil community. 

The mechanical de-compaction proposed for restoration is experimental, with little known efficiency 

coefficients and may not go as deep as some existing compaction, thereby potentially masking 

compaction in the root zone. The heavy de-compaction machinery itself causes compaction and other 

types of soil damage.

No depths of existing compaction are disclosed nor are areas and depths of proposed mechanical 

amelioration disclosed in the DEIS. No accounting of net soil conditions expected after the timber 

sale include any efficiency factors for the proposed de-compaction devices.

Subsoiling effects on weed spread are discussed in the FEIS (FEIS pg. 3.9-9) and described in more detail 

below. The Soil Scientist also discusses the effectiveness of decompaction with a SGR (FEIS pg. 3.5-24

thru 3.5-26). Depth of compaction is disclosed (FEIS pg. 3.5-10, 3.5-28, 3.5-30, 3.5-35).

Subsoiling with the SGR was completed in 2008 in the Hayes Creek area on the Bitterroot NF. Recent 

monitoring compared soil pits in subsoiled areas to soil pits in compacted areas, and found:

the entire soil profile was decompacted in the subsoiled areas

soil moisture was 4% to 40% greater in subsoiled area soil pits 

soil horizons were intact and not mixed

Soil infiltration increased in the subsoiled areas. 

Mixing surface organics and vegetation could lead to the  ̳burning up of organics‘; however monitoring 

indicates soils were not detrimentally disturbed. Vegetative growth is more prolific on the subsoil sites due 

to increased infiltration and moisture in the rehabilitated soils. The increased vegetative biomass on the 
Response to Comments

Lower West Fork Project Final EIS 4-19

subsoil sites will in turn build organic horizons more quickly than the compacted soils – another benefit of 

decompaction. 

Spotted knapweed was abundant in several of the monitoring locations before subsoiling. Monitoring 

indicates that subsoiled areas do not have more knapweed than the adjacent compacted areas. The grasses 

were more prolific on the subsoiled areas, which over time may out-compete and reduce the knapweed 

population. Rhizomatous weeds may spread with subsoiling so areas with rhizomatous noxious weeds 

should be avoided. 

Additional time will be required to note changes in vegetation from subsoiling at the Hayes Creek site since 

only 1 year of recovery has been monitored. Detrimental surface disturbances from the excavator itself 

were not noted. The excavator has low ground pressure (5 1⁄2 psi) and even if compaction was created by 

the machine, the SGR works behind the equipment to decompact soils. More importantly, subsoiling will 

be done only where compaction already exists, so potential compaction from the excavator is negligible. 

The complete description of subsoiling monitoring (Monitoring of Subsoiling, Hayes Creek, Bitterroot NF, 

2009) is available in the project file (PF-SOIL-011).

A study by Otrosina, Sung, and White (1996) indicated that subsoiled plots had increased fungal biomass 

when compared to compacted thinning plots and undisturbed control plots. The study was completed in the 

Sierra Nevada Range in California and included sampling sites on loam/clay loam soils and on granitic 

soils with coarse sandy loam texture. These soils are similar to those found on the Idaho batholith on the 

Bitterroot NF. The study noted that subsoiling increased the production of fine root biomass, which 

contains significantly higher amounts of mycorrhizae than soil alone (Sung et al. 1995). 

FOB/WWI-16: As discussed and disclosed in the DEIS, the anticipated increase in DSD due to 

proposed activities is significantly lower than the best available science indicates. There is available 

agency science quite specific to the conditions here in the Bitterroot. This underestimation in the 

LWF DEIS runs counter to the best available agency science of expectable DSD....This does not 

agree with the best BNF specific, long-term DSD monitoring reported in 2005 (MEF DEIS) by 

McBride.

The BNF has recent monitoring data that reflects the impacts from current logging technology (Forest Plan 

Monitoring and Evaluation Reports 2006, 2007, 2008). Recent monitoring data is the most valid; past 

monitoring efforts followed different methodologies, which provided misleading results. In many cases, 

any soil disturbance was considered detrimental during past soil monitoring, which is not an accurate 

reflection of soil conditions.

In addition, newer harvest systems and silvicultural prescriptions have led to improved soil protection. 

FOB/WWI-17: ...the LWF DEIS fails to disclose analysis of DSD caused by burning slash piles... 

This factor must be included in LWF EIS soils analysis.

The effects of burning piles are disclosed in the FEIS (FEIS pg. 3.5-19 thru 3.5-20). Additional DSD 

analysis of burning large slash piles (greater than 100 ft2) and not located on landings will be included in 

the FEIS (FEIS pg. 3.5-20). Most large slash piles are burned on landings and do not lead to additional 

DSD because the landings are considered permanent infrastructure. 

FOB/WWI-18: Unless this condition is met directly under the piles it may be meaningless because 

the piles intercept precipitation potentially leaving the ground under them drier than ground at that 

location not under the piles.

The intent of this mitigation is to ensure soil conditions are moist when the piles are burned. You are 

correct that piles intercept moisture so soils beneath the piles may potentially be drier than the surrounding 

soils. However, burning the piles when the surrounding soils are moist will protect soils better than when 

soil conditions are dry. Burning during warm and dry conditions is also highly unlikely because the risk of 

fire escape would be high.
Response to Comments

Lower West Fork Project Final EIS 4-20

FOB/WWI-19: As requested in our scoping comments, total acreage of road surface, including 

temporary, in each activity area should be displayed alongside the detrimental soils condition 

information.

Detrimental soil information for each unit is in the project file (PF-SOILS-009). The information in this 

spreadsheet includes the existing DSD, DSD from proposed activities including temporary roads, and 

expected amount of improvement in soil condition from rehabilitation activities. National Forest system 

roads are part of the forest infrastructure and are removed from the productive land base. Therefore, 

system roads do not count towards DSD (R1 SQS) and are not included in the soils analysis.

FOB/WWI-20: Soil conditions, including roads and areas with detrimental soil damage, should be 

mapped and disclosed on a sub-watershed basis within the project area in order to assess cumulative 

impacts. This is important in the disclosure of cumulative watershed impacts because detrimental 

soil compaction would add to impacts from road compaction, ECAs and hydrophobic soils (DEIS, 

p.3.5-7) in increased and flashier water runoff, which causes higher high flows, lower low flows, and 

bank instability. (See esp. Lavene Creek section below)

Soil monitoring was conducted on each harvest unit. Detailing exact locations of soil compaction over the 

entire project area is not necessary to the analysis because the effects of compaction are localized to the 

area of impact. Soil monitoring has been completed on the proposed activity areas and the data is located 

in the project file (FEIS pg. 3.5-32 to 3.8-34, PF-SOIL-002 and 010). Cumulative soil impacts from past 

management in the project areas are discussed in the FEIS (FEIS pg. 3.5-35 thru 3.5-42). 

The effects of compacted soils on watershed conditions are evaluated in the watershed analysis. Road 

densities and ECAs were analyzed on a subwatershed basis (PF-WAT-4). The analysis identified 

subwatersheds at risk, such as Lavene Creek, because of high road densities or ECAs. The ID Team 

modified the unit treatment or applied mitigation measures, such as wider buffers, that addressed the level 

of risk in the subwatershed. See also the response to FOB/WWI-30.

FOB/WWI-21: These ancient debris flow relics tell us that the 2000 fires were not outside the range 

of historic variability. There have been many such events over thousands of years. These land forms 

silently disagree with your rationale for logging to save the soil from dreaded “highly severe” forest 

fire “outside the historic range of variability”.

You are correct that debris flows are part of the natural soil disturbance regime. However, fire suppression

has altered stand conditions in the project area. Overcrowded stands and high fuel loads increase the 

potential for high severity fire in the project area, and high severity fires degrade soils (Elliot and 

Robichaud 2001, FEIS 3.5-7, 3.5-9). 

FOB/WWI-22: Unit 1 has existing DSD on 19% of the unit. Even with the proposed mitigation of 

ground skidding only in winter conditions, an increase in soil compaction is inevitable.... Newer, 

more stringent requirements may also be unexpectedly ineffective and should not be relied upon in 

areas already over SQS “limits”.

The Interdisciplinary Team modified the treatment of the portion of Unit 1 with high DSD (65 acres below 

NFSR 363) in Alternative 3. The modified treatment would meet the purpose and need, prevent additional

soil disturbance, and provide conditions that would enhance soil rehabilitation. This alternate treatment 

pertains only to the part of the ground-based yarding portion of the Unit. Proposed activities for the skyline 

portion of the Unit 1 and the area of ground-based yarding without high DSD would not change in 

Alternative 3. 

In the modified treatment, non-commercial size trees would be cut down using hand tools; the slash would 

be left on the ground for one year so nutrients could leach into the soils (Palviainen et al. 2004; Baker et al. 

1989). A prescribed fire would then be ignited to reduce fine fuel loads. Following the under burn, coarse 

woody debris levels would be assessed and additional trees (8 inch dbh and greater) would be felled to 
Response to Comments

Lower West Fork Project Final EIS 4-21

meet 15 to 20 tons of coarse woody debris needed for soil rehabilitation and to create adequate spacing to 

meet silvicultural objectives. Some branches may need to be distributed through this part of the Unit to 

spread out fuels. If high concentrations of branches increase fire potential, the excess slash would be hand 

piled and burned. Ground-based equipment would not be needed for this treatment so there would be no 

additional DSD.

FOB/WWI-23: It is not clear in the DEIS if only the 55 acres of winter ground skidding or all of Unit 

1 would receive the slash blanket treatment.

The 55 acres of winter ground skidding was a mistake in the DEIS. Winter ground skidding would occur 

on the 65 acres below NFSR 363 in Alternative 2. This is the only part of Unit 1 with high DSD and the 

only part scheduled for winter logging. The remainder of the Unit 1, above NFSR 363, does not have soil 

disturbances that exceed R1 SQS. 

Soil mitigation for Unit 1 is listed in the FEIS on pages 2-18, 2-19 and 3.5-26. Mitigations for the 65 acres 

below NFSR 363 in Alternative 2 include winter logging and leaving 15 to 20 tons/acre of coarse woody 

debris on site for soil recovery. The rest of Unit 1 would be harvested under the same guidelines and 

criteria of the other units and coarse woody debris would average 5 to 10 tons/acre (FEIS pg. 3.5-13). 

Treatment of Unit 1 below NFSR 363 in Alternative 3 is described above (FOB/WWI-22). Treatment for 

the remainder of Unit 1 (above NFSR 363) under Alternative 3 would be the same as for Alternative 2.

FOB/WWI-24: The DEIS does not appear to disclose the additional DSD attributable to the new 

“temporary” road planned for Unit 1 nor does it appear to disclose the additional 2% DSD 

expectable from burning slash piles (MEF DEIS, p. 3.5-25)

Because of the many undisclosed factors (unspecified amelioration techniques, lack of amelioration 

effectiveness coefficients, unaccounted temporary road and slash burning DSD), it is impossible for 

the Decider or public to intelligently anticipate the soil conditions in Unit 1 upon implementation.

Soil analysis for Unit 1 includes the disturbances from the temporary road (PF-SOILS-009). The 

temporary road proposed in Unit 1 is outside of the portion of the Unit with high DSD. Higher amounts of 

coarse woody debris will be retained across the 65 acres in Unit 1 below NFSR 363 (FEIS pg. 2-18, 2-19, 

3.5-15 thru 3.5-17). Alternative 2 does not include burning in the 65 acres below NFSR 363 in Unit 1

(FEIS pg. 2-11). Because of that, woody debris will be maintained for soil recovery. Soil amelioration 

techniques and their effectiveness are specified and discussed in the FEIS (FEIS pg. 3.5-14 – 3.5-17, 3.5-

24, 3.5-27).

An alternate treatment for the portion of Unit 1 with high DSD is analyzed under Alternative 3 in the FEIS

(see response to FOB/WWI-22)

FOB/WWI-25: ...Thus, Unit 1, with 19% existing DSD would receive additional (even more than the 

DEIS reports) DSD from proposed logging, new roads and slash pile burning followed by only the 

cursory rehabilitation of leaving slash, which admittedly “does not immediately restore soils to predisturbance levels”.

This does not satisfy R1SQS requirement that “the cumulative detrimental effects from project 

implementation and restoration should not exceed the conditions prior to the planned activity”.

If the BNF assertion that this proposed activity in unit 1 fits within the R1 SQS is allowed to stand, it 

clearly shows that the R1 SQS is arbitrary and capricious and is not sufficient to protect soils per the 

NFMA mandate. 

The legitimacy of the R1 SQS needs to be challenged in specific cases. Unit 1 is a good example.

The 15% areal extent of soil disturbance is the limit where impact to soil productivity may be measurable. 

The temporary roads exist in the unit and new roads would not be constructed. In Alternative 2, no burning 

is proposed in the portion of the unit with high DSD and it would only be logged in winter over snow, 
Response to Comments

Lower West Fork Project Final EIS 4-22

which would prevent new soil impacts. Leaving high levels of slash on-site restores components of the soil 

forming processes that will enhance soil development. Granted this is not as instantly gratifying as 

applying a treatment that would immediately restore conditions to pre-disturbance levels but it accelerates

the soil recovery process.

NFMA states that ―soil, slope, or other watershed conditions will not be irreversibly damaged‖(36CFR sec 

1604g(E)(i)), and ―...such cuts are carried out in a manner consistent with the protection of soil...and the 

regeneration of the timber resource.‖ (36CFR sec 1604g (F)(v)). Under Alternative 2, timber in Unit 1 

below NFSR 363 would be harvested in winter, high levels of coarse woody debris would be left 

throughout that portion of the Unit, and fire would not be prescribed to treat the slash. These practices 

would prevent irreversible damage to the soils in this area, accelerate the soil recovery process, and be 

consistent with the protection of soils. 

The ID Team modified the treatment of Unit 1 below NFSR 363 in Alternative 3 to respond to the concern 

of high DSD that would increase with timber harvest (FEIS pg. 2-13). The modified treatment in 

Alternative 3 would achieve the project purpose and need without the use of heavy machinery in the area. 

The treatment is described in FOB/WWI-22. The environmental effects analysis of the No Action 

alternative (Alternative 1), and these two action alternatives in the FEIS provides the Deciding Officer and 

the public a clear basis of choice between the alternatives (40CFR 1502.14). 

FOB/WWI-26: ... please disclose on maps and discuss all site specific watershed work, road 

restoration and road use restrictions that were planned under previous NEPA decisions within the 

proposed project area....In cases where the planned restoration was required to bring the project 

area into compliance with Forest Plan standards, the result has been that projects outside legal limits 

defined by Forest Plan standards have been implemented in anticipation of restoration benefits that 

never arrived....It will give the public and decision maker tools to help measure the likelihood that 

various aspects of the project will actually get done within the “Temporal Scope” described as 10 

years at DEIS p.1-13

In the Lower West Fork analysis area, most of the work identified in previous environmental analyses has 

been completed. 

The FEIS summarizes watershed work completed over the last 12 years authorized under three 

environmental assessment decisions: Nez Perce Watershed Restoration and Travel Management (1997), 

Burned Area Recovery Project (2001), and Frazier Interface (2003) (FEIS pg. 3.6-8).

Nez Perce Watershed Restoration and Travel Management (1997)

28 roads identified for watershed improvement treatments

Watershed work completed on 27 roads

NFSR 1347 still needs watershed improvement work

Phase I completed in 1998

Phase II completed in 1999

Burned Area Recovery Project (2001): This is the only project where watershed work was needed to 

offset effects predicted by modeling of the fire, proposed timber harvest, and fuel treatment. No 

harvest or prescribed fire was analyzed in the Lower West Fork portion of the Burned Area Recovery 

analysis area.

NFSR 13431 listed for storage; completed in 2006

NFSR 49: gravel placement on about 2/3 of the road in 2008; remainder expected to be completed 

in 2009

NFSR 49, lower crossing, installed fish passage culvert; completed in 2008 and 2009
Response to Comments

Lower West Fork Project Final EIS 4-23

NFSR 731, East Piquett Road: gravel placed in 2008 on about one mile of road near the stream, 

beginning with the first wet crossing, including the crossing with East Piquett Creek, and 

continuing to the switchback.

The culvert on NFSR 731, at the East Piquett crossing, was replaced with a fish passage pipe in 

2009

NFSR 5723 and 5724: Gravelling crossings and BMP upgrades have not been accomplished to date 

because road improvement funds have focused on roads that parallel streams or produce a lot of 

sediment such as NFSR 723 (Jennings Camp), NFSR 725 (Meadow Creek), NFSR 321 (North 

Fork Rye).

Frazier Interface (2003)

3 miles of BMP road upgrades completed in 2005

NFSR 363 and 5729: shaping and gravelling the road surface 

NFSR 73438: culvert removal and soils revegetated and planted with shrubs.

NFSR 5729, Baker Creek crossings, gravel surfacing scheduled for 2009

5 culverts identified for replacement for fish passage – not completed. Engineering surveys and 

design are complete on half of them but the project needs funding to purchase the culverts. 

Pierce Creek, NFSR 5629, NFSR 13466; NFSR 363

Baker Creek, main channel, NFSR 5629; north channel, NFSR 5629

BAER funding: NFSR 49 – replaced culvert on unnamed tributary above the gate completed in 2006

NFSR 5634, road to Baker Lake Trailhead, installed 43 dips to recondition and improve drainage; 

completed in 2008.

FOB/WWI-27: FOB would like to see that “assumption” of 10 years for project implementation 

rationalized in the FEIS with the easily available administrative paper work research information we 

have requested.

The project implementation time frame of 10 years is based on the time it takes to layout, contract, harvest, 

and close a timber sale. It also provides flexibility to get prescribed fire burning windows and additional 

funding to implement projects not covered by timber harvest revenues. 

As part of the bull trout consultation process for the Lower West Fork project, the U.S. Fish and Wildlife 

Service directed the Bitterroot NF (Forest) to provide an estimate of the amount of time it would take the 

Forest to complete all of the culvert replacements and removals proposed in Alternatives 2 and 3. The U.S. 

Fish and Wildlife Service needs the estimate in order to adequately analyze effects to bull trout. The ID 

Team developed the 10 year estimate by examining how long it has taken the Forest to complete fish 

culvert replacements and removals. The Forest has been conducting fish culvert replacements and 

removals since 2000 and has replaced or removed 50 culverts for fish passage purposes. For those 50 

culverts, the average time between completion of NEPA and implementation was 3.3 years. The Forest 

currently has 25 fish passage culverts on its backlog list that have NEPA completed and are awaiting 

implementation. For the backlog culverts, the average number of years since NEPA was completed is 4.3 

years. The Forest is currently replacing or removing 2-4 fish culverts per year. At that rate, and 

considering the Forest‘s performance since 2000, 10 years is a reasonable estimate of the time it will take to 

replace or remove all of the fish passage culverts in the Lower West Fork project (USDA Forest Service, 

2009: Item 21 and 41).

FOB/WWI-28: The LWF FEIS should disclose which restoration activities are needed to bring the 

project into compliance with applicable standards and laws and which restoration activities are 

magnanimously meant to improve the situation over and above legally defined limits in the project 

area. Given that additional certain damage, FOB wants solid, dependable assurance in the FEIS and 
Response to Comments

Lower West Fork Project Final EIS 4-24

Record of Decision that the restoration work described in the LWF project will be done in a timely 

manner if the commercial logging is done.

The Lower West Fork analysis area complies with applicable environmental standards and laws. Forest 

Plan goals are to maintain or improve water quality and quantity (Forest Plan pg II-3). Forest Plan 

objectives are to manage riparian areas to prevent adverse effects on channel stability and fish habitat 

(Forest Plan II-6). INFISH amended the Forest Plan and the requirements include maintaining stream 

buffers in riparian habitat conservation areas (FEIS pg. 2-19, 2-20, 3.6-1, 3.7-34). The restoration activities 

planned in this analysis are to maintain or improve watershed conditions. This project complies with the 

Forest Plan by designating riparian habitat conservation area buffers wide enough to prevent sediment from 

reaching the streams (FEIS pg. 2-19, 2-20, 3.6-40, 3.7-15) and proposing road treatments that reduce road 

related sediment and improve watershed conditions (FEIS pg. 3.6-41). The Montana Streamside 

Management Zone Act requires buffers between the stream and activity units. The Stream Management 

Zone (SMZ) defined by this law is narrower than that required by INFISH. Since the Forest complies with 

the INFISH riparian habitat conservation areas, it is also in compliance with the SMZ Act (FEIS pg. 2-20, 

3.6-1, 3.6-41, 3.6-42). The Water Quality Restoration Plan and Total Maximum Daily Loads for the 

Bitterroot Headwaters Planning Area (Restoration Plan) (DEQ 2005) was developed to comply with the 

Clean Water Act. The Restoration Plan assigned a road sediment reduction target (FEIS pg. 3.6-1, 3.6-2). 

The watershed restoration activities proposed in either action alternative would move toward the assigned 

target by reducing sediment contribution points throughout the analysis area (FEIS pg. 2-26, 2-27, 3.6-21, 

3.6-30, and PF-WAT-31, page 3.3-28, 36, 37). In summary, the restoration activities planned in this 

analysis are to maintain or improve watershed conditions and comply with applicable standards and laws. 

The Hydrology Specialist Report (PF-WAT-31 pg. 3.3-28, 3.3-36, and 37) lists a subset of roads as 

mandatory stewardship items that the ID Team believes would offset potential sediment contributions from 

activities associated with the project. These stewardship items are mandatory because they will be

accomplished as part of the stewardship project; they are not mandatory to bring the analysis area into legal 

compliance. They were selected because they provide the greatest aquatic resource benefit and could 

realistically be completed within the duration of the stewardship contract. 

The mandatory stewardship items were selected from 2006-2007 field investigations that identified roads 

and culverts contributing sediment to streams. The roads selected in Alternative 2 are those that contribute 

the most sediment and therefore the highest priority for treatment (Table 2). The cost of treatment would 

be about $93,850. The same road treatments in Alternative 2 were selected for Alternative 3 with the 

addition of NFSR 13424 and the removal of four culverts (Table 3). Road treatment costs under 

Alternative 3 are about $108,200. These road treatments would be completed under the stewardship 

contract and prior to contract closure. 

The remainder of the restoration opportunities (optional stewardship items) also provide aquatic resource 

benefits and would be completed as funding is available.

Table 2: Mandatory Stewardship Items to Benefit Aquatic Resources under Alternative 2

Road Number Watershed # Culverts 

Removed

# of Culverts

Contributing Sediment Miles Treated

13411 E. Piquett 4 2 0.8

13411 E. Piquett 1 0 0.4

13457 E. Piquett 0 0 1.8

13466 Pierce 3 2 0.6

13830 Violet 2 2 1.6

13831 Violet 2 2 1.3
Response to Comments

Lower West Fork Project Final EIS 4-25

Road Number Watershed # Culverts 

Removed

# of Culverts

Contributing Sediment Miles Treated

13836 E. Piquett 2 2 2.4

13434 Piquett 1 1 2.7

13287, 74321 Piquett Repair Sediment Sources

Total 15 18.7 tons annual reduction 11.6

Table 3: Mandatory Stewardship Items to Benefit Aquatic Resources under Alternative 3

FOB/WWI-29: Table 3.6-2 on DEIS p.3.6-8 should include a column disclosing the expected increase 

in sediment delivery to each stream from log hauling.

Such a column has been included in the FEIS (FEIS pg. 3.6-9) but there is no scientific model is available 

that can quantitatively estimate sediment delivery to streams from log hauling. The amount of sediment 

delivered to streams during log hauling depends on several site-specific variables, with the most important 

ones being the condition of the road during the haul (e.g. wet roads versus dry roads), and the distance of 

the road from streams (FEIS pg. 3.7-15 thru 3.7-17). Generally, dry haul roads produce very little 

sediment, while wet roads have the potential to deliver large amounts of sediment (FEIS pg. 3.7-15, 3.7-

16). With careful sale administration and proper adherence to the hauling mitigation measures (FEIS pg. 2-

20), the Forest Hydrologist and Fisheries Biologist expect sediment delivery from log hauling will not be 

measurable or visible in the stream bottom (FEIS pg. 2-26, 2-27, 3.7-17). Our log haul monitoring supports 

this prediction (FEIS pg. 3.7-16, 3.7-17). 

FOB/WWI-30: Critical information necessary to estimate impacts of project activities on water 

yield, sediment delivery and their cumulative effect on channel stability is missing from the LWF 

DEIS. Water yield and sediment delivery are both affected by soil conditions in addition (or 

multiplication?) to the ECA measurement.

The ID Team disagrees, and believes that satisfactory information needed for the decision maker is 

presented in both the DEIS and FEIS and summarized below. The DEIS, FEIS, and project file references 

can be reviewed for more detail. 

Road Number Watershed # Culverts 

Removed

# of Culverts 

Contributing 

Sediment

Miles 

Treated

13411 E. Piquett 4 2 0.8

13411 E. Piquett 1 0 0.4

13424 Piquett 4 2 2.9

13457 E. Piquett 0 0 1.8

13466 Pierce 3 2 0.6

13830 Violet 2 2 1.6

13831 Violet 2 2 1.3

13836 E. Piquett 2 2 2.4

13287 Piquett Repair Sediment 

Sources

Total 18 20.4 tons annual 

reduction 11.8
Response to Comments

Lower West Fork Project Final EIS 4-26

Equivalent Clearcut Area (ECA) is a simplified version of WRENSS model (USDA, 1974). The 

Hydrologist used this model to evaluate the effects of past projects on current conditions and flag 

watersheds where high water yields may be a concern. Watersheds with an ECA over 25% indicate a need 

for additional analysis and possibly mitigation (FEIS pg. 3.6-5). Subwatershed ECA calculations included 

harvest and known wildfires since 1973 (FEIS pg. 3.6-9 thru 3.6-16, PF-WAT-4). The differences between 

existing conditions and the effects of Alternatives 2 and 3 are described in the FEIS (FEIS pg. 3.6-25 thru 

3.6-29, 3.6-32, 3.6-33). ECA remains well below the 25% threshold after project implementation in 

Boulder, Pierce, Troy, and the Lower West Fork (FEIS 3.6-25, 3.6-28). The highest ECA is 13% in these 

watersheds; a relatively low risk that water yield would increase. The analysis shows East Piquett, Piquett, 

Violet, and Lavene watersheds would be above the threshold, 35, 54, 70, and 28 percent after 

implementation, respectively (FEIS 3.6-26, 3.6-28). Field review found Violet Creek had stable 

streambanks with no evidence of channel downcutting (FEIS pg. 3.6-14, 3.6-28). Channel conditions are 

good in Lavene Creek (FEIS pg. 3.6-13 and PF-WAT-2). For extra protection, a mitigation measure of 

wider RCHA boundaries would be required during ignition of prescribed fires to reduce the risk of 

sediment contributions to the stream (FEIS pg. 2-20, 3.6-28). This additional mitigation measure would 

maintain the present stream channel condition.

The WEPP model estimated that harvest activities may result in minor amounts of erosion within the units, 

no measurable sediment contributions to streams would occur due to RHCA buffers, surrounding 

vegetation mitigation and slope steepness (FEIS pg. 3.6-21,3.6-29, 3.7-14, 3.7-15, PF-WAT-19). 

Monitoring supports this conclusion (USDA 2003-2006, Item 22; FEIS pg. 3.6-21, 3.7-14). Potential 

sediment contributions to streams from prescribed fire raised concerns in Pierce and Lavene watersheds. 

RHCA buffers were widened for the ignition of prescribed fire in Units 32, 33, and 60A to reduce the 

potential that sediment would enter the streams (FEIS pg. 2-20, 3.6-28). Monitoring conducted on harvest 

units between 2003 and 2006 found the filtering capacity of the unburned RHCA prevented prescribed firecreated sediment from crossing RHCAs and entering streams (FEIS pg. 3.7-18). 

Projects that could contribute to cumulative effects are described in the FEIS (FEIS pg. 3.6-34 thru 3.6-39) 

and project file (WAT-31 pg. 3.3-39 through 52). The highest potential of cumulative effects comes from 

roads used during hauling or road decommissioning/storage. All roads that parallel streams have been 

graveled within the past five years (see the responses to FOB/WWI-26 and FOB/WWI-29, and FEIS pg.

3.6-34, 3.7-15, 3.7-16). Except for culvert removals where sediment contributions are certain, the risk of 

measureable cumulative effects from the implementation of Lower West Fork alternatives 2 or 3 is low 

because the potential change in sediment delivery from forest management is low. However, mitigations

(FEIS pg. 2-20, 2-26, 2-27, 3.6-18) would reduce the sediment contributions from restoration work and this 

work would lead to long-term water quality improvement (FEIS pg. 2-26, 2-27, 3.6-21, 3.6-30, 3.7-19).

FOB/WWI-31: Damage maps, and analysis need to be made available to know where potential for 

cumulative problems with areas of high ECAs, burned/hydrophobic soils, high road densities (open 

and closed) and otherwise compacted soils.

The ID Team added a map to the FEIS, Fig. 3.5-1 (FEIS pg. 3.5-31), that displays roads and the area of the 

Rombo fire by subwatersheds, and the calculations of road density are shown in Table 4, below. Figure 

3.3-9 in the FEIS displays fire history from 1970 to the present time. The Rombo Fire is the one large fire 

that may still have hydrophobic soils within the analysis area because it occurred in 2007.

FEIS provides tabular data and associated discussion of the existing ECA in the analysis area 

subwatersheds (FEIS pg. 3.6-9 thru 3.6-16). Comparison of this information to the watershed map (Figure 

3.6-1, FEIS pg. 3.6-3) allows the reader to spatially determine areas with ECA concerns, specifically, 

Violet and Lavene Creek watersheds. Lavene, Troy, and Pierce Creek subwatersheds have the highest road 

densities. RHCAs are wider in these subwatersheds to inhibit sediment potentially created by prescribed 

fire from reaching the streams (FEIS pg. 2-20, 3.6-28). Buffers in Violet Creek were not increased because 

units proposed for commercial activity were farther from the stream than the buffer distance.
Response to Comments

Lower West Fork Project Final EIS 4-27

The Detrimental soil disturbance shown in Table 3.5-3 (FEIS pg. 3.5-5) discloses the area and percent of 

compacted soils. Cumulative effects relative to fire, compacted soils, and timber harvest are discussed in 

the FEIS (FEIS pgs. 3.5-29 – 3.5-34, 3.5-36, 3.5-37) as are cumulative effects relative to roads and ECA 

(FEIS pg. 3.6-34 – 3.6-37).

Table 4: Road Density in the Subwatersheds of the Lower West Fork Analysis Area

FOB/WWI-32: According to the best available DSD history on the BNF (see McBride ref above) 

about 30% DSD on the 98 acres of summer ground skidding can be expected. That would add about 

30 acres to the existing 55 acres, bringing the total DSD to about 49%. With the additional 8% DSD 

expectable from skyline logging (LWF DEIS, p.3.5-17) of 65 acres, over 50% of the unit would suffer 

DSD. This excessive soil compaction will add to the increased volume and flashier runoff attributable 

to the, already over threshold, 27% ECA.

Past soil monitoring followed different methodologies that over-estimated detrimental soil disturbance (PFSOILS-012, PF-SOILS-013) and the data is not valid for estimating potential soil disturbance. Recent 

monitoring follows the protocols established by (PF-SOILS-014) and the data provides an accurate 

reflection of soil conditions and potential DSD. 

Unit 3 straddles the ridge between Lavene Creek and Lower West Fork subwatersheds, and most of the unit 

is in the Lower West Fork subwatershed. The 35 acres of Unit 3 in the Lavene Creek subwatershed is all 

summer ground-based yarding; there is no skyline yarding in the Lavene Creek side of Unit 3. Soil 

rehabilitation following timber harvest would accelerate the natural processes of soil recovery and create a 

net improvement in soil productivity (FEIS pg. 3.5-16 , 3.5-17, 3.5-24 thru 3.5-28). 

The 20-25% ECA threshold triggers a higher resolution analysis; anything below this threshold has a low 

probability of causing a detectable increase in water yield (FEIS pg. 3.6-5). Lavene Creek surveys showed 

channel conditions are good (FEIS pg. 3.6-13). Widening the RHCAs to 300 feet would prevent any 

Subwatershed Name Total Road Density 

(miles/sq mile)

Open Road Density 

(miles/sq mile)

Closed Road Density

(miles/sq mile)

Applebury 0.0 0 0

Baker 0.1 0.1 0

Boulder 0.1 0.1 0

Castle 3.8 0 3.8

Christianson 0.2 0.1 <.1

E. Piquett 3.1 0.8 2.3

Lavene 4.0 2.6 1.4

Lloyd 0.3 0.2 0.1

Pierce 4.9 3.1 1.8

Pine 1.1 0.1 1.0

Piquett 2.8 0.7 2.1

Steep 3.5 0 3.5

Troy 5.1 0.1 5.0

Violet 9.2 2.2 7.0

Ward 2.8 1.9 0.9
Response to Comments

Lower West Fork Project Final EIS 4-28

sediment produced by prescribed burning from reaching the stream (FEIS pg. 3.6-28; see also response to 

FOB/WWI-30).

FOB/WWI-33: How much additional sediment from dust and runoff at crossings is expected from 

hauling unit 4?... Channel instability in Lavene Creek as well as sediment fro dust and runoff could 

carry sediment into the West Fork at high water events in Lavene Creek. Additional sediment would 

violate the TMDL prescription for the West Fork and thereby violate the Clean Water Act..

For the reasons described in our response to FOB/WWI-29, accurately quantifying sediment delivery from 

log hauling is not possible. Though dust is an inconvenience to people, dust particles are too fine to 

accumulate on stream bottoms and impair fish habitat quality. Also, most dust particles never reach stream

surfaces because they are intercepted by vegetation and eventually wash to the ground during rains. The ID 

Team expects hauling on NFSR 5630 (the Lavene Creek Road) will not contribute measurable amounts of 

sediment to Lavene Creek because: 

(1) NFSR 5630 has been gravel surfaced and BMP upgraded 

(2) the width of the flat, well-vegetated riparian vegetation filter strip averages about 100 feet 

between NFSR 5630 and Lavene Creek (FEIS pg. 3.7-16). 

All of the stream crossings on Lavene Creek have also been gravel surfaced, are not excessively steep, and 

would be protected with straw bale check dam mitigation (FEIS pg. 2-20, 3.7-16, 3.7-17). 

Lavene Creek stream survey found stream channel stability was ―good‖ and conditions were similar to 

reference streams (FEIS pg. 3.6-13). Although ECA calculations are near the level of concern, there is a 

wide, low gradient buffer between the road and the stream that would trap sediment before it reaches the 

stream (FEIS pg. 3.7-16, 3.7-17). In addition, straw bale sediment filters would be installed at points along 

the road where sediment could enter the stream (FEIS pg. 2-20, 3.7-17). Monitoring has shown this 

treatment is an effective way of preventing sediment from entering streams. Log hauling on NFSR 5630 

with the mitigations in place would not contribute sediment to Lavene Creek and would not violate the 

Clean Water Act or TMDL recommendations in the Restoration Plan.

FOB/WWI-34: Alternative 2 treats about 3,200 acres of potential and suitable marten and fisher 

habitat, about 18% of suitable habitat in the project area. (DEIS, p 2-25). This seems like a lot to take 

away from the fisher, when they are having such a hard time.

Treating potential and suitable marten and fisher habitat does not make it unsuitable habitat. While suitable 

marten and fisher habitat will be treated in Alternatives 2 and 3, the key characteristics of this habitat will 

not be changed. Therefore, the proposed actions would not preclude the animals from using the habitat

(FEIS pg. 3.8-29—3.8-31). Though the ID Team acknowledge the potential that fisher may use parts of the 

habitat less, the coarse woody debris, snag, and RHCA standards and mitigations outlined in the Forest 

Plan and FEIS would ensure that travel, resting, hiding, hunting, and denning habitats would be retained 

throughout the treatment area. 

Neither of the action alternatives would affect fisher population viability because of the large amount of 

suitable fisher habitat on the Bitterroot NF and adjacent national forests, and the minor impacts the 

proposed treatments would have on marten and fisher habitat. If an individual happened to occupy an area 

during treatment, there is a large amount of suitable habitat within the Lower West Fork analysis area and 

adjacent landscape to which they could be displaced. In conclusion, implementation of either Alternative 2 

or 3 may impact individual marten, fishers, or their habitat, however it would not likely contribute to a 

trend towards the loss of population viability for either species (FEIS pg. 3.8-30), and the potential effects 

of the proposed alternatives on suitable marten and fisher habitat are minimal in the context of Forest-wide 

habitat.

Forest monitoring information indicates marten populations are stable and well distributed (PF-WL-012). 

Less information is known about the populations of fisher on the Bitterroot NF; however trapping records 
Response to Comments

Lower West Fork Project Final EIS 4-29

of fisher in the Bitterroot Valley show the quota has been met for the past ten years. This implies a healthy 

population present on the Forest. 

FOB/WWI-35: Additionally, after thinning the accessibility to snowmobiles will increase, further 

diminishing fisher habitat effectiveness. This impact needs to be disclosed in the FEIS and mitigation 

via area closures analyzed.

The FEIS must disclose any impacts to fisher from increased snowmobile use due to improved 

accessibility after thinning. Mitigation by area closures should be part of the project.

Current cross-country and winter road snowmobile use is restricted to the lower elevations and usage is 

light-to-moderate (FEIS pg. 3.12-12). Recreational use is predicted to remain light even though forest 

canopy openings may facilitate access (FEIS pg. 3.12-12). Though crown and tree spacing would be wider 

in the treatment areas, the remaining stands would be fully stocked and not invite cross-country 

snowmobile use. Area closures are not necessary as mitigation measures since a relatively small portion of 

the habitat would be affected. Riparian corridors and old growth stands would retain habitat components 

that provide resting, foraging, and dispersal opportunities; snags and coarse woody debris will be retained 

in treatment units (FEIS pg. 3.8-26 –3.8-28). Fisher prefer forests with continuous cover and use forested 

riparian areas with late successional stage vegetation extensively for foraging, resting, and as travel 

corridors (Claar et al 1999). 

Scientific literature focusing on the effects recreational activities have on fishers is limited. Direct human 

activity, in general, has been documented to have little effect on fisher movements (Heinemeyer & Jones 

1994). However, management activity may indirectly lead to negative impacts on populations (Claar et al 

1999). Snowmobile trails may be used by trappers and can thus increase the vulnerability of fisher to 

trapping mortality and overharvesting. Fisher are a low-density species with large home range sizes and 

low fecundity rates, which makes the species vulnerable to local extinctions through overharvesting. 

However, if management planning is done on a landscape scale while incorporating the concept of refugia, 

as is done with this project, negative effects on fisher due to recreational activities are minimized. The 

Selway-Bitterroot Wilderness and Inventoried Roadless Area, Allan Mountain Roadless Area, riparian 

areas, and old growth stands provide refuge for fisher adjacent to the treatment units. Snowmobile activity 

may affect individuals on a site-specific basis, but would have a low impact on populations.

FOB/WWI-36: The 2005 map made changes to road designations without proper environmental 

analysis, and therefore illustrates many roads as open to vehicles up to 50” in width where those 

vehicles were in fact prohibited by previous NEPA decisions. 

It is apparent that the BNF did not comply with NEPA requirements when it updated its Visitor and 

Travel Map in 2005, as it changed the protections established in prior decision documents that 

ensured compliance with NEPA, NFMA, and other environmental mandates.

These changes were done by fiat with no NEPA analysis or public process and no science to show any 

differences in impacts between full-sized vehicles and smaller motorized vehicles. regarding the 

resources in question. Where is the science?

The 2005 Visitor Map and its compliance with NEPA and NFMA are not analyzed in this project. The 

Lower West Fork ID Team made recommendations for travel management in the analysis area based on 

resource needs and conditions. 

FOB/WWI-37: In your discussion of Travel Management Direction you should identify the authority 

and make available in the LWF FEIS documentation of the decision to open code “90”, R-4, R-6 or 

R-7 roads to ORVs.

The authority to manage a transportation system resides in 36 CFR 212 subparts A, B, and C. A point of 

clarification about ORVs: the Bitterroot NF manages the above route classes for ATVs. ATVs are defined 

as, ―All terrain vehicle/quadracycle – any motorized off highway vehicle 50 inches or less in width, having 
Response to Comments

Lower West Fork Project Final EIS 4-30

a dry weight of 600 pounds or less that travels on three or more low-pressure tires with a seat designed to 

be straddled by the operator. Low-pressure tires are 6 inches or more in width and designed for use on 

wheel rim diameters of 12 inches or less, utilizing an operating pressure of 10 lbs per square inch (psi) or 

less as recommended by the vehicle manufacturer.‖ (2005 Forest Visitor Map). These routes are also open 

to motorcycle use. 

FOB/WWI-38: The BNF appears to have opened up a large amount of ML 1 roads to ORV use 

without NEPA and without changing the maintenance level designations.

This situation must be disclosed and discussed within the LWF FEIS. How many miles of R-4, R-6, 

R-7, code 90 roads fall within the LWF project area? What were the purposes of original NEPA 

closures? What are the names of the original NEPA documents that authorized the original yearlong 

closures?

In the Lower West Fork project area there are approximately 200 miles of road

R-4: 61.5 miles

R-6: 30.9 miles

R-7: 2.1 miles

Code 90: 1.2 miles

NEPA documents that address travel management in the project area are:

1987 Bitterroot National Forest Plan, Appendix K

No travel management specific to Lower West Fork Project Area

Burned Area Recovery EIS – signed 2001

Travel Management not changed in Lower West Fork Project Area

Piquett Violet Area EA – signed April 1987

Purpose: roads closed for elk habitat effectiveness

EHE in Piquett 3rd order drainage is 44%

EHE in East Piquett 3rd order drainage is 43%

EHE in Violet 3rd order drainage is 49%

No roads specifically mentioned.

Buck Little Boulder EIS – signed August 1993

7.7 miles of road overlap in Lower West Fork project area

Purpose: watershed restoration

Decision: Close to all motorized vehicle use

Practice: restricted seasonally 10/15 – 6/15 to vehicles < 50 inches wide (ATVs can use roads 

between 6/15 and 10/15). 

Castle Creek II EA – signed June 19901

8.3 miles of road overlap in Lower West Fork project area

Purpose: fisheries and water quality

Decision: Close 4 roads, NFSR 74338, 74339, 74605, 74606

Practice: 5 roads closed yearlong to motorized vehicle use; 4 roads closed yearlong to full-size 

vehicles and restricted seasonally 10/15 – 12/1 to vehicles < 50 inches wide (ATVs cannot use 

roads between 10/15-12/1).

1

In the EA Supplement 2, page 4, paragraph 5 states the following: ―A Forest 

Service interdisciplinary (ID) team, which includes the Forest hydrologist, 
Response to Comments

Lower West Fork Project Final EIS 4-31

inspected existing roads, road stream crossings, and skid trails to determine the 

need for sediment mitigation (Agreement, p. 1). The needed measures include: 

1. two road closures with revegetation in 1990, 

2. two road closures with revegetation in 1993, 

3. gravel road surfacing at three road stream crossings, 

4. stream bank riprap at toe of road fill with straw bale at cross drain 

outlet, 

5. mulch and netting application on fill slope of main existing stream 

crossing, 

6. existing skid trail revegetation, 

7. addition of drive-through dips and culverts to existing roads, 

8. planting existing skid trails and closed roads with trees. 

These measures are documented on a map in the project file.‖

Nez Perce Watershed Restoration and Travel Management DM – signed October 1997

21.8 miles of road overlap in Lower West Fork project area

Purpose: Not stated

21.0 miles of road managed consistent with the decision

0.2 miles managed more restrictively:

Decision: on 74347 operate at R-3 restricted 10/15 to 6/15 to all motorized use 

Practice: operates as R-7 closed yearlong to full size vehicles, restricted 10/15 to 6/15 to 

vehicles < 50 inches wide

0.6 miles managed less restrictively:

Decision: on 13466 operate at R-3 restricted 10/15 to 6/15 to all motorized use 

Practice: operates as R-2 restricted 10/15 to 12/1 to all motorized vehicles 

FOB/WWI-39: Specifically we ask that you disclose if these roads have factored into the LWF EIS 

resource impact analyses just as they would if they were open seasonally to full size vehicles. If not, 

why not. 

How does the opening of these roads impact the watershed problems that caused their former closure 

after NEPA analysis and authorization? How does their opening affect wildlife security regarding 

hunting, calving and winter forage?

All roads, open or closed, were considered in the watershed analysis. Inventories conducted on all roads in 

the analysis area occurred in 2005 and 2006 (PF-WAT-27). All crossings were reviewed and identified as 

either contributing or not contributing (FEIS pg. 3.6-8, PF-WAT-16). The roads are considered as impacts 

on the landscape and treated the same as an open road as long as they are on the system. A stored road that 

is re-opened is analyzed as a temporary road and appropriate mitigation and restoration are applied (PFWAT-23).

EHE analysis was reviewed between the DEIS and the FEIS. The analysis was based on open roads. Open 

roads are defined as roads open to full-sized vehicles during all or part of the year (FEIS 3.8-15 –3.8-17, 

3.8-23 –3.8-26). Route density was also calculated in the analysis area though there is not a Forest Plan 

standard that addresses this use relative to wildlife (FEIS 3.8-15, 3.8-16). Routes are typically roads that 

are closed to full-size vehicles but open year-long or seasonally to other motorized use. In the Lower West 

Fork analysis, the ID Team proposed closing roads by storage or decommissioning but did not propose 

opening closed roads for public travel. Some closed or non-system roads may be re-opened to access 

timber harvest units but they will be stored or decommissioned following use. Any roads that may be 

opened for timber harvest access are well outside of the security areas (FEIS 3.8-16, 3.8-19, 3.8-24).
Response to Comments

Lower West Fork Project Final EIS 4-32

FOB/WWI-40: Allowing ORVs to go around locked gates directly causes damage by forcing 

vehicles off the road prism. It also trains-in and sends a clear message that reinforces the already 

prevalent notion that it‟s OK to drive off road and around locked gates.

Allowing OHVs to drive around the gates may not be the best method of providing access but options are 

limited when full sized vehicle access is needed at some times of the year or in the near future. Allowing 

OHV access on some roads closed to full sized vehicles is a common practice on the Bitterroot NF. Road 

signs posted at the road closure gate indicate accepted travel method and season of use for roads. While 

some travel restrictions may be violated by irresponsible users, monitoring all gates for appropriate use at 

all times is difficult. The Bitterroot NF employ a full time OHV ranger who monitors OHV use and gate 

effectiveness on the Forest, and maintains or replaces gate signs when needed. The Lower West Fork 

analysis does not recommend opening roads or allowing OHV use on roads currently closed to that use. 

When OHVs travel on roads not designated for that use, law enforcement is notified and they investigate 

the matter.

FOB/WWI-41: Any categorical distinction between roadless land and unroaded land is divorced 

from the land itself. It is simply administrative, certainly not ecosystem oriented. Our concern is for 

the biological value of the land and water.

With your language and approach, you cloud important ecological considerations about the land by 

sowing doubt with allusions to the credibility of the messenger. Whatever acres of land are unroaded 

(no quotes) on the ground have the same potential values as any other roadless land.

The distinction between Inventoried Roadless Areas and unroaded areas exists because Inventoried 

Roadless Areas must be managed under administrative protections. The criteria for inclusion in Roadless 

Areas are discussed in the FEIS (FEIS pgs. 3.12-4, 3.12-7). The Bitterroot NF recognizes that unroaded 

lands have values similar to those in Inventoried Roadless Areas (FEIS pg. 3.12-4, 3.12-10). The Forest 

Wilderness Coordinator analyzed the unroaded areas in the Lower West Fork analysis area in the context of 

the resource values listed in Table 3.12-1 (FEIS pg. 3.12-4) and the potentially unroaded areas are

displayed in Figure 3.12-1 (FEIS pg. 3.12-5). The effects on the five roadless area attributes of the

unroaded areas are on page 3.12-14 through 3.12-18 of the FEIS.

The use of quotes on the word  ̳unroaded‘ was not meant to sow doubt about anyone‘s credibility but to 

display the ID Team‘s uncertainty that no roads exist in the unroaded areas. During field reconnaissance, 

the ID Team found several unmapped, constructed roadbeds that will be useful to current management and 

may be useful in the future. Many people assume that if an area is described as unroaded, it is pristine and 

has never been managed. This is not the case as displayed in Figure 3.12-2 (FEIS pg. 3.12-15).

FOB/WWI-42: Where is the 1.4 miles of “temporary” road that would be built in unroaded land, 

according to Table 3.12-3? It does not seem to be on the map. This information should be disclosed 

on a map in the FEIS.

FOB strongly opposes road building in both unroaded and roadless areas

The temporary roads that extend into the unroaded lands are shown on the alternative maps and Figure 

3.12-1 (FEIS pg. 3.12-5).

FOB/WWI-43: Allan Mountain IRA is part of a critical hub of linkages connecting the Salmon 

Selway ecosystem with the Sapphire Crest route to the Northern Continental Divide ecosystem as 

well as the route south along the Divide to the Yellowstone ecosystem. Failure to disclose impacts on 

biological corridor values in the DEIS is a serious flaw.

The Lower West Fork analysis area includes 9,494 acres of the 104,069 acres Allan Mountain IRA that is 

on the Bitterroot National Forest. No treatments are proposed in this roadless area. There would be no 

direct effects on wildlife in the Allan Mountain IRA from this project (FEIS 2-33, 2-35, 2-36, 2-37). The 

areas closest to the Roadless Area would remain unchanged in the long term. Major linkages between 
Response to Comments

Lower West Fork Project Final EIS 4-33

refugia and various ecosystems are not interrupted in the current landscape patterns any more than they 

were by the fire in the past. The Selway-Bitterroot Wilderness, Selway-Bitterroot roadless area, and the 

Allan Mountain roadless area provide large refuge areas for fisher. The riparian linkages will remain intact 

because no timber harvest will occur in them. The units around the riparian areas will also retain habitat 

components important to fisher though crown closure would be less than 100 percent (FEIS 3.8-29 –3.8-31.

Additionally, the Forest Plan presents no regulatory directions addressing animal movement, migration, and 

dispersal with which the Forest Service must comply (FEIS pg. 3.8-66). 

FOB/WWI-44: We believe that road prisms make the most identifiable and manageable boundaries 

for roadless and unroaded areas. Areas without roads are then truly identified as roadless areas.

Though road systems are definitely identifiable features, they are not the only features that can be used to 

identify boundaries. Roads adjacent to unroaded areas detract from the integrity, naturalness, and solitude 

values of the areas because of the noise and dust from vehicle use and the potential for vehicle trespass into 

roadless areas. Slope breaks and other topographic features that block the sights and sounds of roads and 

other types of human activity make good identifiable and manageable boundaries and protect the values of 

the unroaded environment. 

FOB/WWI-45: According to p. 3.12-9, stumps within areas without roads reduce the Apparent 

Naturalness of an area, thereby diminishing Wilderness Characteristics. This policy is misdirected, 

but given its use, we therefore oppose thinning in areas without roads identified on the FOB 

roadless/unroaded map.

What is stated on page 3.12-10 in the FEIS (DEIS 3.12-9) under the heading of Apparent Naturalness is, 

―Apparent Naturalness depends on scale. If a visitor were to focus on the immediate vicinity while in the 

unroaded land, it would seem somewhat natural as described in the preceding paragraph (Natural Integrity). 

Looking at the area from a landscape perspective, the presence of existing roads, past timber harvest, and 

the heavy use of some trails by motorcycles and/or OHVs would decrease this perception of apparent 

naturalness.‖ There is a high level of forest management that has occurred in and adjacent to the unroaded 

blocks adjacent to the IRAs. While the areas still retain a natural appearance they do not singly or 

collectively add to the characteristics valued in IRAs. The steep topography of the unroaded blocks and 

adjacent roads inhibits a sense of solitude and remoteness because the roads are within view and the sounds 

of motorized vehicles carry through the area. Adding these areas to the IRAs would not buffer the IRAs 

from the managed areas or add to wilderness characteristics of the IRAs. 

The following table discloses the area of thinning proposed under Alternatives 2 and 3 in the unroaded 

areas

Table 5: Area of thinning Proposed in Unroaded Areas in the Lower West Fork Analysis Area under 

Alternative 2 and Alternative 3

Alternative 2 

(acres)

Alternative 3 

(acres)

Commercial Thin 308 292

Non-Commercial Thin 13 5

USEPA-1: Based on the procedures EPA uses to evaluate the adequacy of the information and the 

potential environmental impacts of the proposed action and alternatives in an EIS, the DEIS has 

been rated as Category EC-2 (Environmental Concerns -Insufficient Information) due to potential 

for at least short-term sediment effects from proposed management activities.

Noted - See responses to comments below and additional analysis in the FEIS when necessary.
Response to Comments

Lower West Fork Project Final EIS 4-34

USEPA-2: We appreciate the inclusion of clear narrative discussions describing alternatives, as well 

as the tables presenting important information and features of the alternatives, and tables comparing 

alternatives, and color foldout alternatives maps in Chapters 2 (Tables 2-2 to 2-8). We also 

appreciate inclusion of the information on BMPs and Cumulative Effects included in the Appendices. 

The narrative, tables, maps, figures and appendices facilitate improved project understanding, help 

define issues, and assist in evaluation of alternatives providing a clearer basis of choice among 

options for the decisionmaker and the public in accordance with the goals of NEPA.

Thank you.

USEPA-3:: The EPA supports conduct of improve forest vegetation management activities to reduce 

fire risks and resilience to fire, and insects and disease. We encourage planning and conduct of 

vegetation management activities in a manner that minimizes adverse environmental effects, and 

addresses watershed restoration, particularly for a project in the watershed of a water quality 

impaired stream included on Montana's Clean Water Act Section 303(d) list (West Fork Bitterroot 

River)....

We are pleased that each of the action alternatives includes activities to improve watershed 

conditions (i.e., road storage and decommissioning, removing culverts that increase sediment 

production and/or serve as fish barriers, and restoring soil in areas impacted by prior terracing 

disturbances).

Noted

USEPA-4: There appear, therefore, to be environmental and resource management trade-offs 

associated with selecting between Alternatives 2 and 3. However, we support Alternative 3 over 

Alternative 2 due to the improved potential for watershed and water quality improvement and 

reduced impacts to fish habitat likely to occur with Alternative 3. We consider such benefits of 

Alternative 3 to be important because the West Fork Bitterroot River is a water quality impaired 

stream, and the project area is within the Bitterroot Headwaters Total Maximum Daily Load 

(TMDL) Planning Area.

Noted

USEPA-5: We generally favor understory thinning from below, slashing and prescribed fire to 

address fuels build-up with reduced ecological impacts. We also favor retention of the larger more 

vigorous trees, particularly trees of desirable tree species whose overall composition is in decline. We 

particularly support conduct of activities to restore Ponderosa pine and western larch. The larger 

healthier trees are generally long-lived and fire resistant, and provide important wildlife habitat.... If 

the forest canopy is opened too much by removal of large fire resistant trees it may promote more 

vigorous growth of underbrush and small diameter trees that would increase fuels and fire risk in 

subsequent years, contrary to the fire risk reduction purpose and need....

The Lower West Fork project appears to be generally consistent with these measures, particularly 

the need to restore fire as a natural disturbance process and to retain and promote Ponderosa pine.

Noted

USEPA-6: It would be helpful if the extent of proposed harvest of large trees of desired species in 

Lower West Fork harvests were more clearly identified in the FEIS.

The location for proposed harvest of trees in excess of 6.5 inches dbh is identified as ―Commercial Thin 

(acres)‖ in Table 2-2: Unit Treatments Under Alternative 2 (FEIS pg. 2-6, 2-7). Unit numbers and acres are 

displayed in the table. The information is also displayed in maps Figure 2-1: Vegetation Treatments in 

Alternative 2 and Figure 2-2: Vegetation Treatments in Alternative 3 (FEIS pg. 2-30, 2-33). 
Response to Comments

Lower West Fork Project Final EIS 4-35

The desired stand conditions by VRU are described in the FEIS (FEIS pg. 3.2-17 thru 3.2-20). The effects 

of commercial thinning are described in the FEIS (FEIS pg. 3.2-28 thru 3.2-32). The purpose of the 

commercial thins is to retain large, ponderosa pine and, to a lesser extent, Douglas fir in the stands. While 

some large trees would be harvested to achieve the desired spacing, the Forest Service does not know how 

many. The map titled Figure 3.2-2: Forest Size Classes in the Lower West Fork Analysis Area depicts

treatment units and tree sizes classes in the analysis area (FEIS pg. 3.2-13). In the DEIS, this map was 

titled Figure 3.2-2: Cover Types in the Lower West Fork Analysis Area. Similarly Figure 3.2-1: 

Vegetation Response Units (VRU) in the Lower West Fork Analysis Area provides information about the 

biological capabilities and disturbance processes in each treatment unit (FEIS pg. 3.2-7). The associated

species mix for each VRU is described in the FEIS on pages 3.2-5 through 3.2-10.

USEPA-7: The Bitterroot National Forest should coordinate their proposed activities in the West 

Fork Bitterroot River watershed with Montana DEQ TMDL program staff to assure consistency of 

proposed activities with the State's Bitterroot Headwaters TMDL (contact Mr. Robert Ray at 406-

444-5319).

DEQ was contacted to notify them that the DEIS was in the planning stages and a copy was sent to the 

agency. DEQ often relies on EPA to review Forest Service EISs and notify DEQ if they need to get 

involved (pers. comm. Robert Ray June 26, 2009). DEQ also stated, ―Based upon EPA‘s review, without 

taking the time to look at the EIS, my response is to support EPA‘s recommendation for Alternative 3, as 

likely to be consistent with the TMDL.‖

USEPA-8: our general recommendations regarding roads for your information.

→ minimize road construction and reduce road density as much as possible to reduce potential 

adverse effects to watersheds; 

→ locate roads away from streams and riparian areas as much as possible; 

→ locate roads away from steep slopes or erosive soils; 

→ minimize the number of road stream crossings; 

→ stabilize cut and fill slopes; 

→ provide for adequate road drainage and control of surface erosion with measures such as 

adequate numbers of waterbars, maintaining crowns on roads, adequate numbers of rolling 

dips and ditch relief culverts to promote drainage off roads avoid drainage or along roads and 

avoid interception and routing sediment to streams; 

→ consider road effects on stream structure and seasonal and spawning habitats; 

→ allow for adequate large woody debris recruitment to streams and riparian buffers near 

streams; 

→ properly size culverts to handle flood events, pass bedload and woody debris, and reduce 

potential for washout; 

→ replace undersized culverts and adjust culverts which are not properly aligned or which 

present fish passage problems and/or serve as barriers to fish migration; 

→ use bridges or open bottom culverts that simulate stream grade and substrate and that 

provide adequate capacity for flood flows, bedload and woody debris where needed to 

minimize adverse fisheries effects of road stream crossings. 

We also encourage conduct of inspections and evaluations to identify conditions on roads... that may 

cause or contribute to sediment delivery and stream impairment, and to include activities in the 

project to correct as many of these conditions and sources as possible.

A total of 2.2 miles of temporary road is the only road construction planned. Road segments range in 

length from 0.1 to 0.4 mile. Road construction is limited to temporary roads and has been minimized (FEIS 

pg. 3.6-22 and 3.6-30). Please refer to the mitigation table (FEIS pg. 2-19 thru 2-21).
Response to Comments

Lower West Fork Project Final EIS 4-36

USEPA-9:: ...management direction assures that road maintenance (e.g., blading) be focused on 

reducing road surface erosion and sediment delivery from roads to area streams. Practices of 

expediently sidecasting graded material over the shoulder and widening shoulders and snow plowing 

can have adverse effects upon streams, wetlands, and riparian areas that are adjacent to roads. Road 

use during spring breakup conditions should also be avoided. Snow plowing of roads later in winter 

for log haul should also be avoided to limit runoff created road ruts during late winter thaws that 

increase road erosion

All road maintenance activities, including blading and snow plowing, are required to comply with the U.S. 

Fish and Wildlife Service‘s Programmatic Biological Assessment for Road Maintenance (FEIS pg. 2-20). 

Complying with the Programmatic Biological Assessment would ensure that the concerns expressed in this 

comment are adequately met. The Forest has been closely monitoring its winter log hauls (FEIS pg. 3.7-16, 

3.7-17) and is documented in the project file (PF-FISH-4, PF-FISH -5, and PF-FISH -6).

USEPA-10: If there are road maintenance needs on unpaved roads adjacent to streams and wetlands 

we encourage utilization of such training (contact Donna Sheehy, FS Rl Transportation Management 

Engineer, at 406-329-3312).

We also note that there are training videos available from the Forest Service San Dimas Technology 

and Development Center for use by the Forest Service and its contractors (e.g., "Forest Roads and 

the Environment"-an overview of how maintenance can affect watershed condition and fish 

habitat;...

Noted

USEPA-11: Wetland impacts should be avoided, and then minimized, to the maximum extent 

practicable, and then unavoidable impacts should be compensated for through wetland restoration, 

creation, or enhancement

All wetlands would be designated, marked, and protected as RHCAs (FEIS pg. 2-19, 2-20), and as such, 

would be protected from timber harvest and potentially negative effects from prescribed burning (FEIS pg.

2-19, 2-20). With these mitigations, wetlands are unlikely to be negatively affected by the Lower West 

Fork project (FEIS pg. 3.6-42, 3.6-43).

USEPA-12: It is important that proposed activities be consistent with the riparian management 

objectives described in the ICB Strategy... We are pleased that all timber management activities 

would be conducted to comply with INFISH standards and guidelines avoiding harvest in Riparian 

Habitat Conservation Areas (RHCAs) buffers; no timber harvest and no equipment operation would 

occur in wetlands and appropriate use of BMPs to all harvest and vegetation management activities 

(page 3.6-36, 3.6-42).

The Lower West Fork project is consistent with the riparian goals and riparian management objectives in 

the INFISH strategy (USDA Forest Service, 1995b; FEIS pg. 3.7-34). As such, the project is also believed 

to be consistent with the riparian management objectives in the ICB strategy.

USEPA-13: It is important that wetlands are included as RHCAs, and that timber harvest, road 

construction, or operation of heavy equipment not be allowed in wetland areas, We recommend that 

harvest units be reviewed in the field to determine the presence of wetlands and identify wetlands on 

the Sale Area Map and be flagged on the ground so that timber contractors will be able to avoid 

them.

All wetlands would be designated, marked, and protected as RHCAs (FEIS pg. 2-19, 2-20), and as such, 

would be protected from timber harvest (FEIS pg. 2-19), temporary road construction (FEIS pg. 3.7-17), 

and entry of ground-based equipment (FEIS pg. 2-20). During harvest unit layout, timber preparation 

personnel will mark all wetlands and appropriate buffers as RHCAs and designate them on the Sale Area 

Map (FEIS pg. 2-20).
Response to Comments

Lower West Fork Project Final EIS 4-37

Monitoring indicates that marking RHCA boundaries occurs regularly and with few exceptions, they are 

effective in preventing the harvest of trees or use of heavy equipment in the wetlands (Forest Plan 

Monitoring and Evaluation Report, Fiscal Years 2006, and 2007).

USEPA-14: Are any other ground harvest units to be harvested during winter on snow or frozen 

ground to reduce adverse. effects to soils and erosion? Would it be appropriate to use skyline or 

winter harvesting for harvest units on any other such landtypes?

Only Alternative 2 has ground-based winter harvest proposed in Unit 1 below NFSR 363 (65 acres). All 

other ground-based harvest would occur as scheduling permits, in either winter or summer. Unit 1 is an 

exception since high rock content eliminates the possibility of subsoiling to rehabilitate soil compaction. 

Other mitigations and rehabilitation are prescribed to Unit 1 to protect soils (FEIS pg. 3.5-14 thru 3.5-15,

3.5-25). Winter conditions that meet ground-based harvest requirements seldom occur in the project area 

because the ground-based units are at the lower elevations. Unit 1 may not be treated for a number of years 

if winter conditions are not achieved. The ID Team wants to avoid this situation across the project area.

Slope limitations for tractor operations (BMP IV.A.1, 2, 4, 5, IV.B.1) are restricted to slopes less than 35 

percent or 20% adverse. Portions of harvest units on 35 percent slopes or less are designated as tractor 

ground, slopes greater than 35 percent are skyline (FEIS pg. 3.5-17).

USEPA-15: ...we still want to encourage the Bitterroot NF to review proposed measures to protect 

soils and reduce erosion to assure that all of the units with particularly sensitive soils or on landtypes 

with greater vulnerability or risk of detrimental soil disturbance such as erosion, compaction, and 

mass wasting include adequate mitigation measures and/or less damaging harvest methods to avoid 

erosion and other detrimental soil impacts and/or higher levels of sediment production and 

transport.

Sensitive soils are displayed in Table 3.5-1, 3.5-2, and 3.5-3 (FEIS pg. 3.5-4, 3.5-5). Measures to protect 

soils and reduce erosion are displayed in Table 2-6 (FEIS pg. 2-15, 2-16) and discussed in the FEIS on 

pages 3.5-11 and 3.5-12. Mitigation measures are summarized in the FEIS on pages 2-18, 2-19, 3.5-26 thru 

3.5-28.

USEPA-16: We often suggest measures such as use of existing skid trails wherever possible; 

restrictions on skidding with tracked machinery in sensitive areas; using slash mats to protect soils; 

constructing water bars; creating brush sediment traps; adding slash to skid trail surfaces after 

recontouring and ripping; seeding/planting of forbs, grasses or shrubs to reduce soil erosion and 

hasten recovery; as well as recontouring, slashing and seeding of temporary roads and log landing 

areas following use to reduce erosion and adverse impacts to soils.

All activities will follow SWCPs and BMPs (FEIS Appendix A). Mitigations will be applied to provide 

additional protection where needed (FEIS pg. 2-18 thru 2-20, 3.5-26 thru 3.5-28).

USEPA-17: ...we appreciate the identification and the extent to which timber harvest, temporary 

road construction, timber discussion of harvest and prescribed burning would take place on sensitive 

soils in the Lower West Fork Project, and the consideration that has been given to mitigation of soils 

impacts.

Noted

USEPA-18: We are pleased that coarse woody debris would be retained (from 5 to 24 tons per acre 

depending on fire group) on harvest sites to help maintain soil productivity (Table 3.5-5, page 3.5-13). 

It is important that adequate woody debris is retained on site to maintain soil productivity. We are 

also pleased that previously disturbed terraces would be restored in both action alternatives.

Noted 
Response to Comments

Lower West Fork Project Final EIS 4-38

USEPA-19: It is important that field soil monitoring and analysis take place to verify that the Region 

1 soil quality thresholds are not exceeded, particularly on the sensitive landtypes. Will field soil 

monitoring allow quantification of benefits to soils that may be restored on the previously disturbed 

terrace areas?

Field monitoring provided the information needed to quantify detrimental soil disturbance (DSD) (FEIS pg.

3.5-1, 3.5-5, 3.5-6, PF-SOILS-009). Post treatment monitoring will be done on a portion of the terrace 

units and subsoiled areas as part of annual forest plan monitoring to assess treatment affects.

USEPA-20: We believe monitoring should be an integral part of land management

The Bitterroot NF annually monitors land management activities and publishes the results in the Forest 

Plan Monitoring and Evaluation Report. The latest report is on the Bitterroot NF web site and listed under 

Projects and Plans (http://www.fs.fed.us/r1/bitterroot/projects/). Monitoring associated with the Lower 

West Fork project is described in the FEIS on pages 2-24 and 2-25.

USEPA-21: The EPA particularly believes that water quality/aquatics monitoring is a necessary and 

crucial element in identifying and understanding the consequences of one's actions, and for 

determining effectiveness in BMPs in protecting water quality... BMPs... need to be monitored to 

verify their effectiveness... We encourage adequate monitoring budgets for conduct of aquatic 

monitoring to document BMP effectiveness and long-term water quality improvements associated 

with road BMP work and road decommissioning.

We generally recommend that more aquatic monitoring be included in projects, using aquatic 

monitoring parameters such as channel cross-sections, bank stability, width/depth ratios, riffle 

stability index, pools, large woody debris, fine sediment, pebble counts, macroinvertebrates, etc,. 

Biological monitoring can be particularly helpful, since monitoring of the aquatic biological 

community integrates the effects of pollutant stressors over time and, thus, provides a more holistic 

measure of impacts than grab samples.

...recognizing that there are limited resources for monitoring, we can accept a lesser level of aquatic 

monitoring for this project. We note that there may be PACFISH/INFISH Biological Opinion (PIBO) 

monitoring sites in the project area that could also be used to help evaluate actual project effects 

(http://www.fs.fed.us/biology/fishecology/emp/index.html). If there are PIBO monitoring sites in the 

area they should also be considered for their potential to evaluate project effects.

Monitoring of fisheries resources in the Lower West Fork project area is described on pages 2-24 and 2-25 

of the FEIS. Biological monitoring of fish populations (before and after treatments) would occur in the 

four streams (Pierce, Lavene, Piquett, and East Piquett creeks) where effects to fish populations could most 

likely occur (for detailed historical information on these sites, see PF-FISH-1). Fish habitat monitoring 

would consist of monitoring water temperatures in those same four streams before and after timber harvest 

(FEIS pg. 2-24). One PIBO monitoring site is present in Piquett Creek near our fish population monitoring 

site; a second PIBO monitoring site was established in East Piquett Creek near the Forest boundary in 

2008. The long-term data from the PIBO sites will augment the pre- and post-harvest monitoring data to 

evaluate project effects. 

The Watershed Monitoring Plan is in the project file (PF-WAT-7). The Hydrologist and Fisheries Biologist 

often monitor some of the aquatic monitoring parameters listed above to describe existing conditions (PFWAT-2) and monitor post-treatment when funding is available. In recent years, the Bitterroot NF has 

focused implementation monitoring on effectiveness of treatments to answer questions such as:

1) How effective have revegetation efforts been on roads stored and decommissioned? 

2) Are the closures effective in restricting motorized vehicles?

3) Did RHCA boundaries effectively filter sediment? 

4) Were the mitigation measures implemented and effective?
Response to Comments

Lower West Fork Project Final EIS 4-39

USEPA-22: The DEIS includes a good analysis and discussion of project air quality conditions and 

effects from proposed burning activities (pages 3.3-1 to 3.4-13): We particularly appreciate the 

identification of mitigation measures to reduce air quality impacts (page 3.4-5), and the Tables and 

Figures showing estimated PM 2.5 emissions and downwind levels, which improve understanding of 

potential air quality impacts.

Thank you.

USEPA-23:: It may be of interest to the public to display the website for the Montana/Idaho State 

Airshed Group, http://www.smokemu.org... This is Federal policy which reconciles the competing 

needs to conduct prescribed fires to manage vegetation and restore fire to fire adapted ecosystems 

while at the same time maintaining clean air to protect public health. A copy of the Interim Air 

Quality Policy can be found at: http://www.epa.gov/ttn/oarpgltI/memoranda/fireful.pdf. EPA air 

quality guidance can be found at http://www.epa.gov/air/caa/ .

The FEIS states, ―...though prescribed fires are scheduled to occur during favorable weather forecasts, 

unpredicted weather changes can keep smoke from dispersing as intended‖ (FEIS pg. 3.4-8). Pre-season 

notification letters with maps are mailed to the district mailing list. Individuals wishing to be notified about 

a burn typically contact the ranger district. Interagency Prescribed Fire Burn Plans, Element #11 also 

require that notifications be made prior to implementation.

USEPA-24: It is not clear to us why no use of herbicides is considered in Alternative 3 to control 

weeds that may develop in areas of harvest and road work. We suggest that this be clarified in the 

FEIS.

The Alternatives present a range of activities from which the decision maker can review and select. The 

range of activities chosen in the Record of Decision may contain a mix of activities presented and analyzed 

in the FEIS (40 CFR 1505.1(e)). Alternative 2 displays the potential effects of timber harvest and 

prescribed fire treatments on noxious weeds and the potential need to treat them using herbicides. 

Alternative 3 displays the effects of timber harvest and prescribed fire on noxious weeds without the option 

of treating them with herbicides. This provides a basis for the Deciding Officer to choose whether to 

include the use of herbicides in his decision (40 CFR 1502.14). Though noxious weeds are not treated 

under Alternative 1, other than in areas already covered by other NEPA decision, there are no vegetation 

treatments so it does not display the effects associated with vegetation treatments. The Deciding Officer 

may choose to retain the option of using herbicides to treat noxious weed infestations as analyzed in 

Alternative 2 if she chooses Alternative 3. The effects of using herbicide under Alternative 3 would be less 

than the effects described in Alternative 2 because the harvest area, and therefore the potential herbicide 

treatment area, would be less. 

USEPA-25: We encourage tracking of weed infestations, control actions, and effectiveness of control 

actions in a Forest-level weed database.

The location, size, and composition of new and existing weed infestations are tracked in the NRIS 

TESP/Invasives database. Herbicide treatments and effectiveness are tracked in the FACTS database. 

These are both corporate databases used throughout the Forest Service.

USEPA-26: Measures that we often recommend for preventing spread of weeds from source areas to 

uninfested areas include: 

→ Ensure that equipment tracks and tires are cleaned prior to transportation to an uninfested 

site. 

→ Focus control efforts at trail heads and transportation corridors to prevent tracking of seed 

into uninfested areas. 

→ Attempt to control the spread from one watershed to another to reduce water as a transport 

vector. 
Response to Comments

Lower West Fork Project Final EIS 4-40

→ If a localized infestation exists and control is not a viable option, consider rerouting trails or 

roads around the infestation to reduce available vectors for spread. Establish an education 

program for industrial and recreational users and encourage voluntary assistance in both 

prevention and control activities. 

→ Reseed disturbed sites as soon as possible following disturbance.

Cleaning equipment prior to entering a project area and revegetating disturbed sites are included in all 

timber sale contracts (Contract Provision C/CT6.26) and in mitigation measures (FEIS page 2-18, 2-21).

The other measures listed above are not related to the activities proposed in this project. However, they are 

practices routinely applied through the noxious weed program on the Bitterroot NF. Control efforts are 

concentrated at trailheads and along roads, containment strategies are used if a weed species is restricted to 

one watershed; and education on weed prevention is widely used.

USEPA-27: The greatest vector for spread of weeds is through motorized vehicles-cars, trucks, 

ATVs, motorcycles, and even snowmobiles....

We believe an effective noxious weed control program should consider restrictions on motorized 

uses, particularly off-road uses, where necessary... Restrictions on motorized uses may also be 

needed after burning and harvest activities until native vegetation is reestablished in the disturbed 

areas to reduce potential for weed infestation of the disturbed sites.

Off road travel has been restricted on the Bitterroot NF since 2001. The Forest is currently analyzing travel 

management and will designate trails and areas open for all-terrain vehicle use. In the Lower West Fork 

project, the ID Team proposes to decommission 10 or 27 miles of road in Alternatives 2 and 3, 

respectively, and store 19 miles of road (the same miles of road storage in each alternative).

USEPA-28: Prescribed fire has the potential to stimulate weed growth (e.g., Dalmation toadflax or 

leafy spurge), and can destroy insects planted for biological weed control: We suggest that these 

considerations be evaluated for burn units.

There are no known infestations of Dalmation toadflax or leafy spurge in the Lower West Fork project 

area. Studies on the effects of prescribed fire on leafy spurge biological controls (flea beetles) resulted in 

beetle population increases post-burn. Burns needed to be completed in time for leafy spurge plants to 

resprout prior to beetles emerging (Fellows and Newton 1999). One year after the 2000 fires burned in 

Sleeping Child and Skalkaho drainages flea beetles were found alive on leafy spurge plants (BesslerHackett , personal communication). No research was found on the effects of fire on spotted knapweed 

biological controls, but most likely effects should be minimal if prescribed fires occur when insects are 

dormant (before June and after September).

USEPA-29: Where no native, rapid cover seed source exists, we recommend using a grass mixture 

that does not include aggressive grasses such as smooth brome, thereby allowing native species to 

eventually prevail.

A copy of the Forest Seed Mixes is included in the project file (PF-NOX-001). The Bitterroot National 

Forest no longer uses aggressive exotic grasses like smooth brome, timothy or orchard grass. Some nonnative grasses, like sheep fescue, are used since they are more effective at competing with noxious weeds.

USEPA-30: ...we encourage prioritization of management techniques that focus on non-chemical 

treatments first, with reliance on chemicals being the last resort, since weed control chemicals can be 

toxic and have the potential to be transported to surface or ground water following application.

Our first priority is preventing weed establishment and/or spread. Mitigation measures and contract clauses 

are in effect to reduce the risk of spreading weeds (FEIS 2-21 thru 2-23). Chemicals will only be used in 

areas where preventive measures fail and weeds are found to be encroaching into openings or disturbed 

areas created by the proposed activities.
Response to Comments

Lower West Fork Project Final EIS 4-41

USEPA-31: It is important that the water contamination concerns of herbicide usage be fully 

evaluated and mitigated. All efforts should be made to avoid movement or transport of herbicides 

into surface waters that could adversely affect fisheries or other water uses....

We are pleased that potential effects of use of herbicides on aquatic life has been evaluated (pages 

3.6-23, 3.7-22), and that the herbicides proposed for use have relatively low toxicity (page 3.6-6), 

although some herbicide shown in Table 3.5-8 (page 3.5-22) can exhibit toxicity,

The ID Team evaluates potential herbicide contamination of water in the FEIS (FEIS pg. 3.6-22 thru 3.6-26

and 3.7-23 thru 3.7-28). The ID Team expects that complying with the RHCA spray mitigations in Table 

3.7-4 (FEIS pg. 3.7-26) and the mitigation measures (FEIS pg. 2-21) will keep herbicides out of surface 

waters and protect aquatic life (FEIS pg. 3.7-28). The Bitterroot National Forest conducted a limited water 

quality monitoring during 2004 and 2005 large area aerial spray operations. The Forest Service did not 

detect any herbicide chemicals in nearby streams at the 0.0001 part per million detection limit (PF, FISH10, FISH-11). Drift cards set up along riparian corridors also failed to detect droplets of herbicide (PF, 

FISH-10). Although aerial spraying is not proposed in this project, the risk of water contamination is 

generally higher with aerial spraying than with ground-based spraying. Therefore, the ID Team expects

that since similar mitigation measures were effective in protecting water quality during aerial spraying, they 

have a very good chance of effectively protecting water quality during ground-based spraying activities. 

USEPA-32: It is stated that the maximum application rate of picloram would be 1.0 pound per acre 

(page 3.5-27). We generally recommend that picloram not be used at rates greater than 0.25 lbs/acre, 

and suggest that the Forest Service consider applications of persistent herbicides such as picloram 

only once per year to reduce potential for accumulation in soil.

Picloram will only be used in a few areas usually where access is difficult, due to its longer residual 

properties. Applications will not exceed the allowable rates directed by the chemical label specifications. 

In most cases, picloram application rates will remain much lower than the allowable label rate, For 

example, the control rates the Forest Service uses for spotted knapweed, sulfur cinquefoil, and oxeye daisy 

are 1⁄4 (0.25 lb/ac) of the maximum allowable rate. However, higher rates of picloram are required to 

successfully treat other species such as dalmatian toadflax and leafy spurge (USDA Forest Service 2003a, p 

2-20). Our standard procedure is to apply picloram once per year on a site to stay well within the allowable 

label limits of use. 

In addition, the Forest Service intends to apply a newer herbicide, aminopyralid (brand name Milestone®) 

on most sites instead of picloram because aminopyralid has a shorter residual property, is effective on many 

weed species, and has less impact on non-target species when applied at the recommended rates

USEPA-33: We also recommend that road ditches leading to intermittent and perennial streams be 

flagged as no-spray zones and not sprayed with picloram based herbicides. Herbicides should be 

applied at the lowest rate effective in meeting weed control objectives and according to guidelines for 

protecting public health and the environment.

We are pleased that each of the action alternatives includes activities to improve watershed 

conditions (i.e., road storage and decommissioning, removing culverts that increase sediment 

production and/or serve as fish barriers, and restoring soil in areas impacted by prior terracing 

disturbances).

The ID Team added a mitigation measure to the FEIS that states, ―Dry roadside ditches that lead into 

intermittent and perennial streams will not be sprayed with any herbicides containing picloram.‖ (FEIS pg.

2-22, 2-23).

Herbicides will be applied according to the manufacturers‘ recommendations, which include protection of 

public health and environment. See pages 2-21 to 2-23 and 3.7-26 in the FEIS for mitigation measures 

related to herbicide application.
Response to Comments

Lower West Fork Project Final EIS 4-42

USEPA-34: Tordon 22K herbicide can be applied using wick or carpet roller equipment where drift 

presents a hazard to susceptible crops, surface waters, and other sensitive areas. One part Tordon 

22K is mixed with 2 parts water to prepare a 33% solution. The wick method of application is more 

labor intensive but very effective at targeting particular noxious weeds adjacent to surface waters, 

wetlands, or protected plants.

This method has been used on the Bitterroot NF and will be used if needed to protect sensitive areas or rare 

plants.

USEPA-35: It is important that U.S. Forest Service employees be certified throughout the duration of 

the project. If commercial applicators will be contracted for RUP applications, we recommend 

checking to make sure their MT commercial RUP license is current... Also, please note that 

registration for Access (which has picloram as an active ingredient) is cancelled

All applicators (contract or Forest Service employees) are required to be licensed or supervised by someone 

licensed (FEIS pg. 2-22). Also, all Forest Service applicators receive annual herbicide handling and 

application training approved by the Montana State Dept. of Agriculture. Standard operating contractor 

evaluation procedures require that contract bidders submit documentation that they hold a current 

commercial license in Montana that includes restricted use pesticides (RUPs). The Lower West Fork 

project will follow these standard evaluation procedures. Thank you for the information about Access. 

The Forest Service has not used and does not stock that product on the Bitterroot NF.

USEPA-36: Some suggestions we have to reduce potential water quality and fisheries effects from 

herbicide spraying are to assure that applicators: 1) are certified and fully trained and equipped with 

the and appropriate personal protective equipment; 2) apply herbicides according to the label; and 

3) herbicide applicators should take precautions during spraying...4) no herbicide spraying will 

occur in streams and wetlands or other aquatic areas (seeps, springs, etc,); 5) streams and wetlands 

in any area to be sprayed be identified and flagged on the ground to assure that herbicide applicators 

are aware of the location of wetlands, and thus, can avoid spraying in or near wetlands; 6) use 

treatment methods that target individual noxious weed plants in riparian and wetland areas 

(depending on the targeted weed species, manual control or hand pulling may be one of the best 

options for weed control within riparian/wetland areas or close to water).

Thank you for your suggestions and know the Forest Service follows them. See the above response 

concerning the training and certification of Forest Service herbicide applicators. Forest Service applicators 

are equipped with personal protective gear and equipment that exceeds label requirements. Applicators are 

required to use the appropriate herbicides near riparian zones and live water. Contract inspections and 

supervisor monitoring insure that applicators comply with these requirements. All applicators have 

reviewed and are provided with copies of any applicable NEPA mitigation measures involving herbicide 

application practices, including applications in riparian or wetland areas or close to water. Mitigation 

measures for herbicide use adjacent to riparian and other aquatic areas are included in the FEIS (FEIS pg.

2-21 thru 2-23, 3.7-26). Precautions herbicide applicators take during spraying are in the FEIS (FEIS pg. 2-

22, 2-23). Hand-pulling is used on small, new weed infestations where it is economically feasible.

However, hand pulling is not very effective at controlling rhizomatous weeds such as oxeye daisy and St. 

Johnswort.

USEPA-37: We also recommend that weed treatments be coordinated with the Forest botanist to 

assure protection to sensitive plants, and coordinated with fisheries biologists and wildlife biologists 

to assure that sensitive fisheries and wildlife habitat areas are protected. Please also note that there 

may be additional pesticide use limitations that set forth geographically specific requirements for the 

protection of endangered or threatened species and their designated critical habitat. This 

information can be found at http://www.epa.gov/espplbulletins.htm.
Response to Comments

Lower West Fork Project Final EIS 4-43

Thank you for the information regarding geographically specific pesticide limitations to protect threatened 

and endangered species and their designated critical habitat. Bitterroot NF staffs responsible for protection 

and management of threatened and endangered species review the literature for new developments in 

pesticide effects and coordinate with the Forest Invasive Plants and Rangeland Program Manager. The 

Forest Botanist, and south zone fisheries and wildlife biologists were part of the interdisciplinary team that 

developed the herbicide spray restrictions for this project. The Fisheries Biologist expects restrictions on 

herbicide spraying in RHCAs (FEIS pg. 2-22, 3.7-26) will satisfactorily protect threatened bull trout and 

their critical habitat, and sensitive westslope cutthroat trout and their habitat (FEIS pg. 3.7-28). The Forest 

Botanist will be contacted prior to off-road herbicide applications to avoid sensitive plant habitats, and 

herbicides will not be applied in sensitive plant locations (FEIS 2-21). 

USEPA-38: You may also want to consider use of a more selective herbicide (clopyralid) for use in 

conifer associated communities to reduce impacts on non-target vegetation. We also note that 

spotted knapweed, which is a prevalent noxious weed species in western Montana, is nonrhizomatous and should be relatively easy to control with lower rates of the most selective low 

toxicity herbicides.

The Bitterroot NF routinely uses clopyralid on noxious weeds to protect conifers, rare plants, and other 

non-target species. As noted above in USEPA-32, the lowest rate possible will be used to control target 

weed species. The Forest Service agrees that spotted knapweed can be controlled with lower rates of 

herbicides than other weed species. 

USEPA-39: ...the website for EPA information regarding pesticides and herbicides is 

http://www.epa.gov/pesticides/... http://nptn.orst.eduftech.htm... has a wealth of information on 

toxicity, mobility, environmental fate on pesticides that may be helpful (phone number 800-858-

7378)..

Thank you for the website link information.

USEPA-40: We support protection of old growth habitats and maintenance or restoration of native, 

late-seral overstory trees and forest composition and structure within ranges of historic natural 

variability.

Thank you for your support.

USEPA-41: ...we do not oppose underburning to reduce fuel loads and ladder fuels in old growth, 

since it lessens the threat of stand removal by a wildfire and reduces competition with other 

vegetation to promote large diameter trees. Careful prescribed burning in old growth stands can 

reduce fuel loads and fire risk in such stands, and thus, may promote long-term protection and 

sustainability of old growth stands.

Thank you for your support

USEPA-42: The DEIS states that proposed timber harvest and burning will reduce snags and cavity 

habitat in 13% of the project area in Alternative 2 and (page 38-13), but that 2-5 to 10-15 snags 

would be retained depending upon the habitat type (page 1-11)

Snags will be left unless they present an OSHA hazard during timber harvest. Some snags may burn during 

prescribed burning but other snags may be created through the same activity.

USEPA-43: If it is determined that the finally selected project alternative could adversely affect any 

threatened or endangered species (e.g., gray wolf, lynx) the final EIS should include the associated 

U.S. Fish & Wildlife Service (USFWS) Biological Opinion or formal concurrence for the following 

reasons: 

(a) NEPA requires public involvement and full disclosure of all issues upon which a decision is to be 

made; 
Response to Comments

Lower West Fork Project Final EIS 4-44

(b) The CEQ Regulations for Implementing the Procedural Provisions of NEPA strongly encourage 

the integration of NEPA requirements with other environmental review and consultation 

requirements so that all such procedures run concurrently rather than consecutively (40 CFR 

1500.2(c) and 1502.25); and 

(c) The Endangered Species Act (ESA) consultation process can result in the identification of 

reasonable and prudent alternatives to preclude jeopardy, and mandated reasonable and prudent 

measures to reduce incidental take.

... EPA recommends that the final EIS and Record of Decision not be completed prior to the 

completion of ESA consultation. If the consultation process is treated as a separate process, the 

Agencies risk USFWS identification of additional

The FEIS will be released to the public prior to completing ESA consultation with the U.S. Fish and 

Wildlife Service. However, the Record of Decision will not be signed until all ESA consultation is 

completed. Upon release of the FEIS, the U.S. Fish and Wildlife Service has 135 days to write a Biological 

Opinion or 30 days to issue a concurrence letter. As soon as the Bitterroot NF receives a Biological 

Opinion or concurrence letter from the U.S. Fish and Wildlife Service, those documents will be placed in 

the project file. In 2008, Forest fisheries biologists presented the Lower West Fork project to the Western 

Montana Bull Trout Level I Team. The team consists of U.S. Fish and Wildlife Service fisheries biologists 

and fisheries biologists from the western Montana National Forests and Bureau of Land Management. The 

team provided a critical review that helped shape the project and avoid potential consultation pitfalls. Also, 

the Forest recently completed consultation on two other neighboring projects (the Trapper Bunkhouse FEIS 

and Selway-Bitterroot Wilderness Invasive Plants Management Project FEIS). The issues and lessons 

learned during those two consultations have been incorporated into the Lower West Fork consultation.
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-1

APPENDIX A

BEST MANAGEMENT PRACTICES

BITTERROOT NATIONAL FOREST

INTRODUCTION

Best Management Practices (BMPs) are the primary mechanism to achieve water quality standards 

(Environmental Protection Agency 1987). This Appendix describes the Forest Service BMP process in 

detail; it lists the key Soil and Water Conservation Practices (SWCP) selected for use on the Bitterroot 

National Forest and describes each SWCP that may be refined to address site-specific conditions. This 

process determines project level BMPs that protect beneficial uses and meet water quality objectives. It 

also cross-references the Montana Department of Natural Resource Conservation BMPs (State BMPs) that 

each SWCP addresses, contains information related to implementation and planning review, and lists the 

contractual clauses needed to make the SWCPs a legal requirement in a timber sale. The appendix also 

addresses the effectiveness of selected BMPs. 

BMPs include, but are not limited to, structural and non-structural controls, operations, and maintenance 

procedures. BMPs can be applied before, during, and after pollution-producing activities to reduce or 

eliminate the introduction of pollutants into receiving waters (40 CFR 130.2, EPA Water Quality Standards 

Regulation). Usually BMPs are applied as a system of practices rather than a single practice. BMPs are 

selected on the basis of site-specific conditions that reflect natural background conditions and technical and 

economic feasibility.

The Bitterroot National Forest Plan states "Soil and Water Conservation practices will be a part of project 

design and implementation to ensure soil and water resource protection” (Forest Service Handbook 

2509.22, Forest Plan, pg II-25). Montana State Water Quality Standards require the use of Reasonable 

Land, Soil, and Water Conservation Practices (analogous to BMPs) as the controlling mechanism for 

nonpoint source pollution. Use of BMPs is required in the Memoranda of Understanding between the 

Forest Service and the State of Montana as part of our responsibility as the Designated Water Quality 

Management Agency on National Forest System (NFS) lands.

The Practices described herein are tiered to the practices in FSH 2509.22. They were developed as part of 

the NEPA process, with interdisciplinary involvement, and meet Forest and State water quality objectives.

BMP IMPLEMENTATION PROCESS

In cooperation with the State, the USDA Forest Service primary strategy to control nonpoint sources is 

implementation of preventive practices (BMPs) determined necessary to protect identified beneficial uses.

The Forest Service Nonpoint Source Management System consists of:

1. BMP selection and design based on site-specific conditions; technical, economic and institutional 

feasibility; and the designated beneficial uses of the streams.

2. BMP application before, during and after land management activities;

3. BMP monitoring to ensure the practices are implemented and effectively protect designated 

beneficial uses.

4. Evaluation of BMP monitoring results.

5. Applying monitoring results to current/future activities and BMP design. The District Ranger is 

responsible for insuring that this BMP feedback loop is implemented on all projects.
Appendix A – Best Management Practices

A -2 Lower West Fork Project Final EIS 

1. BMP Selection and Design. Forest Plans identify water quality goals. These goals meet or exceed 

applicable legal requirements, including State water quality regulations, the Clean Water Act, and the 

National Forest Management Act. Project environmental assessments are tiered to Forest Plans during

the NEPA process.

The project interdisciplinary team selects the appropriate BMPs. After identifying the designated 

beneficial uses for the associated streams, the initial list of BMPs is developed from the Forest Plan 

standards and guidelines, Forest Service handbooks, and special provisions identified by watershed and 

fisheries specialists for sensitive areas.

BMP selection and design are dictated by water quality objectives, soils, topography, geology, 

vegetation, and climate. Environmental impacts and water quality protection options are evaluated and 

alternative mixes of practices are considered. A final collection of practices are selected that not only 

protect water quality but meet other resource needs. These final selected practices constitute the 

BMPs.

2. BMP Application. The BMPs are translated into contract clauses, special use permit requirements, 

project plan specifications, and so forth. This ensures that the operator or person responsible for 

applying the BMP is actually required to apply it. Specialists review timber sale contracts to insure 

needed resource protection is included as appropriate legal clauses. Pre-sale crews and engineers take 

the site-specific BMP prescriptions from plan-to-ground during harvest unit and road layout through 

marking, tagging, flagging, tagline surveys, and locating road drainage and stream crossings. This is 

when final adjustments to fit the BMP prescriptions to the site are made before implementing the 

resource activity.

3. BMP Monitoring. During the course of project activities (e.g. timber harvest or road construction), 

timber sale administrators, engineer representatives, and resource specialists ensure that the BMPs are 

implemented according to plan. BMP implementation monitoring is done before, during, and after 

resource activity implementation. This monitoring answers the question: Did we do what we said we 

were going to do? Once BMPs have been implemented, further monitoring is done to evaluate if BMPs 

are effective in meeting management objectives and protecting water beneficial uses. State water 

quality standards, including beneficial uses, are one of the evaluation criteria monitored.

4. BMP Monitoring Evaluation. The technical evaluation of monitoring described above determines

how effectively BMPs protect or improve water quality. Water quality standards and conditions of the 

beneficial uses are one evaluation criteria. If the evaluation indicates that water quality standards are 

not met or beneficial uses are not protected, corrective action considers the following three 

components:

A. The BMP: Is it properly designed, technically sound, and effective? Is there a better practice, 

which is technically sound and feasible to implement?

B. The implementation program or processes: Was the BMP applied as designed? What factors 

were involved in partial, or lack of, implementation – inadequate personnel, equipment, funds, 

or training?

C. State water quality criteria: Do the parameters and criteria used for effectiveness evaluation 

adequately reflect changes in water quality and beneficial uses?

5. Feedback. Response to BMP evaluation is both short- and long-term. Where corrective action is 

needed, immediate response is undertaken. Responses may include: modification of the BMP, 

modification of the activity, or ceasing the activity. BMP evaluations over the long-term may indicate 

trends that require responses or changes in management direction.
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-3

ITEMS COMMON TO ALL SOIL AND WATER CONSERVATION 

PRACTICES

Responsibility for Implementation: The District Ranger is responsible for ensuring the factors identified 

in the following SWCPs are incorporated into the correct timber sale contract provision, that the provisions 

are included in the timber sale contract, or public works contract through the inclusion of specific contract 

clauses, and implemented on the ground. Specific timber sale contract clauses are often included in the 

BMPs for further reference, and the clauses start with a "B" or a "C" followed by a number (e.g. B6.4).

Unless otherwise specified, the Presale Forester is responsible for insuring that the factors identified in the 

following SWCPs are incorporated into the correct timber sale contract B or C provision and that the 

provisions are included in the timber sale contract.

The Timber Sale Administrator or Engineering Representative are the official representatives of the 

Contracting Officer (COR) on timber sale and public works contracts, respectively. They are responsible 

for insuring that the contract clauses are properly administered.

Monitoring: As part of administering the timber sale or public works contracts , the Timber Sale 

Administrator and Engineering Representative monitor BMP implementation. Resource Specialists also 

monitor SWCPs and provide feedback to the contract administrators. 

SOIL AND WATER CONSERVATION PRACTICES IN THE LOWER 

WEST FORK PROJECT

FORMAT OF THE SOIL AND WATER CONSERVATION 

In this section, we list the SWCPs in a table followed by a more detailed description of their application to 

the Lower West Fork project. The table lists the class of SWCP, cross-references State BMPs, the timber 

sale contract clause that implements the SWCP, whether the SWCP applies to the project, and how the 

SWCP is implemented or reviewed. The following definitions assist with reviewing the table:

KEY: CLASSES OF SWCP (BMP)

A = Administrative

G = Ground Disturbance Reduction

E = Erosion Reduction

S = Stream Channel Protection/Stream 

Sediment Reduction

W = Water Quality Protection

ACRONYMS

SAM = Sale Area Map

SMZ = Streamside Management Zone

TSA = Timber Sale Administrator

TSC = Timber Sale Contract

REFERENCES

B clause – standard in all timber sale contracts

C clause – optional in timber sale contract, see “applicable” column for potential inclusion.

# - numerical value, identifying number or dates determined by timber contract officer, specialist, EIS, 

or line officer during contract construction.

SWCP (Soil and Water Conservation Practice) number – From R1-R4 Soil and Water Conservation 

Practices Handbook, FSM2509.22

State BMP reference number from MTDNRC 2004 Best Management Practices for Forestry 

(PF_WAT_08, Trapper-Bunkhouse Project File)

Applicability – does this BMP/SWCP apply to this project?

Planning Review – how is the BMP implemented or addressed in environmental planning for this 

project? 
Appendix A – Best Management Practices

A -4 Lower West Fork Project Final EIS 

The detailed description of the SWCPs applicable to the Lower West Fork project follows the format 

outlined below. Montana State BMPs are not referenced in the detailed descriptions.

Title: Includes the SWCP number and a brief title

Objective: Describes the SWCP objective(s) and the goals of implementation.

Effectiveness: Provides a qualitative assessment of expected effectiveness that the applied measure will 

have on preventing or reducing impacts on water quality. The SWCP is rated High, Moderate, or Low 

based on the following criteria:

A. Literature/Research (must be applicable to area)

A. Administrative studies (local or within similar ecosystem)

B. Experience (judgment of an expert by education and/or experience)

C. Fact (obvious by reasoned [logical] response)

Implementation: Identifies the range of site-specific water quality protection measures to be implemented 

and how the practices are expected to be applied.

Table A-1: Soil and Water Conservation Practices on the Bitterroot National Forest and in Lower West 

Fork Analysis Area. Class SWCP # State BMP Ref.

SWCP Title

TSC ProvisionApplicable? Y/N

Implementation/Planning Review

Section 11 Watershed Management

A 11.01 IV.A.1

Determination of 

Cumulative 

Watershed Effects

NA Y Completed during project planning, refer to 

DEIS

E 11.03 III.D.10

Watershed 

Improvement of 

Roads, OHV Trails 

and Skid Trails

C5.419# Y See watershed improvement list for project

A 11.05 IV.A.1 Wetlands Analysis 

and Evaluation

B6.61 B6.62 

SAM B6.62 

C6.62# 

Y

Wetlands, SMZ, RHCA marked and 

excluded from harvest or equipment entry 

per mitigation (refer to DEIS), law and 

policy. Soil scientist will help mark any 

units identified in mitigation to ensure 

wetlands are properly identified.

A 11.09 III.E.6 Management by 

Closure to Use C5.41# Y

Specifics of closures and affected roads 

identified in TS Contract and enforced by 

TSA (timber sale administrator)

W 11.13

Sanitary Guidelines 

for Construction of 

Temporary Labor, 

Spike, Logging, 

Fire Camps and 

Similar 

Installations

B6.2 Y Applicable only if camps are established 

during logging operation.
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-5

ClassSWCP #State BMP Ref.

SWCP Title

TSC ProvisionApplicable? Y/N

Implementation/Planning Review

Section 13 Vegetation Manipulation

G 13.02

IV.A.1., 

2, 4, 5 

IV.B.1

Slope Limitations 

for Tractor 

Operation (14.07)

C6.4# Y

Tractor units identified in Unit Table, 

restricted to slopes less than 35% or 20% 

adverse.

G 13.03

IV.A.1 

IV.B.1&

2

Tractor Operation 

Excluded from 

Wetlands, Bogs, & 

Wet Meadows

B6.61 B6.422 

B6.62 SAM 

C6.62# 

Y

INFISH prohibits and DEIS supports 

exclusion of tractors from RHCAs 

(wetlands, bogs, wet meadows). These areas 

will be excluded from harvest units.

E 13.04 IV.B.6 

IV.C.1

Revegetation of 

Surface Disturbed 

Areas

B6.6 C6.601# 

C6.633# Y

Revegetation would occur per TSC, seed 

mix identified by Forest Botanist and 

included in TSC.

W none

IV.B.2 

V.C.2,3,

7

Inclusion of 

INFISH (7/95) 

Recommendations

SAM B6.5 Y

Integral part of analysis - RHCA values and 

effects considered. Harvest/treatment must 

be benign or beneficial to fish.

E 13.06 IV.A.1, 

4

Soil Moisture 

Limitations for 

Tractor Operations

C6.4# Y

Summer ground-based operations will be 

completed on dry soil conditions, see soils 

report for details.

A 13.07 Pesticide Use 

Planning Y Incorporated in project planning and design. Addresses in terms of impacts, mitigation.

W 13.08

Apply Pesticides 

According to Label 

and EPA 

Registration 

Directions

Y Mitigation and project design.

WA 13.09

Pesticide 

Application 

Monitoring and 

Evaluation

Y Mitigation and contract administration

A 

W 13.10

Pesticide Spill 

Contingency 

Planning

Y Project design and mitigation.

W 13.11

Cleaning and 

Disposal of 

Pesticide 

Containers and 

Equipment

Y

Project design, mitigation, compliance with 

laws, regulation and proper pesticide 

application.
Appendix A – Best Management Practices

A -6 Lower West Fork Project Final EIS Class SWCP # State BMP Ref.

SWCP Title

TSC ProvisionApplicable? Y/N

Implementation/Planning Review

W 13.12

Protection of 

Water, Wetlands, 

and Riparian Areas 

During Pesticide 

Spraying

Y

Project design, mitigation compliance with 

laws, regulation and proper pesticide 

application.

13.13

Controlling 

Pesticide Drift 

During Spray 

Application

Y

Project design, mitigation compliance with 

laws, regulation and proper pesticide 

application.

Section 14 Timber Harvest

A 14.02 IV.A.2-6

Timber Harvest 

Unit Design 

(14.08, 14.10)

B6.422 C6.4# 

C6.6 Y

These provisions are only relevant after all 

presale (design) work is complete.

Skid trails will be identified and authorized 

prior to use and will be about 120' apart, 

existing skid trails will be use when feasible. 

Winter yarding conditions specified in 

mitigation. Refer also to DEIS for 

mitigation and discussion on unit design. 

A 14.03

IV.A.1 –

4, 6 & 

B.1 - 3

Use of Sale Area 

Maps for 

Designating Soil 

and Water 

Protection Needs

B1.1 B.42 

B6.5 B6.42 

B6.61 B6.62 

C6.4 

Y

SAM will identify protected stream courses, 

wetlands and riparian areas, slumps and 

other areas excluded from harvest

A 14.04 IV.A.1

Limiting the 

Operating Period 

of Timber Sale 

Activities

B6.65 B6.6 

B6.31 B6.311 

B6.312 

C6.316# C6.6 

Y

Normal operating seasons will be identified 

in the TSC. TSA will monitor conditions 

and enforce as needed.

A 14.05 IV.A.1 Protection of 

Unstable Areas

C6.4# N No unstable (mass-movement-prone) areas 

located during planning or fieldwork

A 14.06 II. (all) 

III.D.10

Streamside 

Management Zone 

Rules, Riparian 

Area Designation

B6.5 B1.1 

C6.4# C6.41# 

C6.50#

Y

SMZ's are typically more narrow than 

RHCA's that will be marked and excluded 

from harvest.
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-7

ClassSWCP #State BMP Ref.

SWCP Title

TSC ProvisionApplicable? Y/N

Implementation/Planning Review

G 14.07 IV.A.2&

4

Determining 

Tractor Loggable 

Ground

B1.1 B6.42 Y

Initially determined during project planning 

in IDT discussions. Will be field checked 

during marking. Refer to mitigation, Soils 

and Watershed reports as well as BMPs 

13.02, 13.03, 14.02, 14.03, 14.05, 14.06, and 

soil moisture limitations.

E 14.08 IV.A.2,4,

5

Tractor Skidding 

Design

B6.422 C6.4# 

C6.42# Y

Mitigation indicates skid trail spacing, Unit 

Table lists units appropriate for ground 

based yarding.

E 14.09 IV.A.1, 2

Suspended log 

Yarding in Timber 

Harvesting

B6.42 B6.5(b)

C6.4# Y

BMP describes requirements for suspended 

(cable, helicopter) yarding. Applicable to all 

non-tractor units, determined by field review 

during planning stages. 

A 14.10 IV.A.6, 

B.4

Log Landing 

Location and 

Design

B6.422 C6.422 Y

Potential landings have been identified and 

reviewed on the ground for accessibility, 

INFISH constraints. Mitigation describes 

treatment after use.

E 14.11 IV.B.4

Log Landing 

Erosion Prevention 

and Control 

B6.6 B6.311 

B6.64 C6.6 

C6.601# 

Y BMP describes design of landings and postuse treatment to minimize erosion 

E 14.12 IV.B.5&

6

Erosion Prevention 

and Control 

Measures During 

Timber Sale 

Operations

B6.6 B6.64 

B6.311 C6.4 

C6.6 C6.601# 

Y

Various mitigations described in DEIS, 

yarding systems identified that minimize 

ground disturbance on sensitive areas. 

E 14.15

IV.B.1,5

&6, 

IV.A.5

Erosion Control on 

Skid Trails

B6.6 B6.311

B6.65 B6.66 

C6.4 C6.6 

C6.601# 

Y

Water bar spacing identified in BMP, skid 

trails no less than 120' apart, limit summer 

skidding based on soil moisture to reduce 

compaction and displacement.

E 14.16 IV.A.1&

5

Meadow Protection 

During Timber 

Harvesting

B1.1 B5.1 

B6.422 B6.61 

C6.4# C6.66 

Y Equipment will be prohibited from entering 

meadows.
Appendix A – Best Management Practices

A -8 Lower West Fork Project Final EIS Class SWCP # State BMP Ref.

SWCP Title

TSC ProvisionApplicable? Y/N

Implementation/Planning Review

S 14.17 IV.A.1&

5

Stream course 

Protection 

(Implementation 

and Enforcement)

B1.1 B6.5 

B6.6 C6.50# 

C6.6 

Y

Stream courses will be identified on SAM, 

excluded from equipment entry (SMZ and 

INFISH), and excluded from treatment area 

or be identified as no treatment zone.

E 14.18

III.E.2, 

8, 

IV.A.5, 

IV.B.4, 6

Erosion Control 

Structure 

Maintenance

B6.67 Y

TSC requires maintenance of erosion control 

structured by purchaser and is monitored by 

TSA

A 14.19

III.E.7, 

IV.A.5, 

B.4, 5, 6

Acceptance of 

Timber Sale 

Erosion Control 

Measures Before 

Sale Closure 

B6.36 Y Direction according to TSC and certification 

by TSA required prior to sale closing.

E 14.20 IV.C 

(all)

Slash Treatment in 

Sensitive Areas

SAM B6.5 

C6.50# B6.7

C6.7 C6.71 

C6.753

Y No dozer-piling proposed, but potential 

excavator piling in some units. 

A 14.22

Modification of the 

Timber Sale 

Contract

B2.37 B8.3 Y Within TSC provision to modify contract for 

resource reasons.

A 14.23 IV.C.1 Reforestation 

Requirement internal Y No reforestation needs identified.

G NA IV.C.3,4,

6

On-site Large 

Woody Residue 

and Soil Litter 

Retention

C6.7# 

C6.406# Y

Silvicultural prescriptions specify the

amount of woody materials to be left on site 

following treatments and is displayed in 

mitigation table. Soil scientist involved in 

final recommendations.

G NA VI. (all) Winter Logging C6.4# Y

Purchaser may work in qualifying winter 

conditions at their discretion. Winter 

ground-based harvest is required in portion 

of unit 1. See soils section in DEIS for 

details.

Section 15 – Roads and Trails

S 15.02

III.A,B,C 

III.D.5, 

IV.A.5

General Guidelines 

for the Location 

and Design of 

Roads and Trails

(124 prmt) Y Applies to any temp roads associated with 

project
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-9

ClassSWCP #State BMP Ref.

SWCP Title

TSC ProvisionApplicable? Y/N

Implementation/Planning Review

E 15.03 III.C.1, 7

Road and Trail 

Erosion Control 

Plan

B6.31, B6.5, 

B6.6, and C6.3 Y

Seeding and fertilizing of reconstruction 

would occur after disturbance, effectiveness 

monitoring would determine if reseeding is 

necessary. Maintenance of haul routes 

would occur as directed by TSA and TSC. 

E 15.04 III.D.4 

III.E.4,7

Timing of 

Construction 

Activities

B6.31 B6.311 Y TSA will monitor conditions and restrict 

when needed to prevent adverse results.

E 15.06 III.D.7, 

III.E.2

Mitigation of 

Surface Erosion 

and Stabilization of 

Slopes

C6.601# Y

No new road construction planned but 

temporary roads would be managed to 

prevent erosion and be stabilized prior to 

sale closure. Refer to DEIS for temporary 

road obliteration requirements.

E 15.07

III.C.1,5 

III.D.2, 

III.E.2

Control of 

Permanent Road 

Drainage

B/C6.6 B6.65 

C6.601 

C5.31# 

C6.661

N

No new road construction associated with 

this proposal. Road improvement work 

would improve road drainage would be 

accomplished under a separate engineering 

contract.

E 15.08 III.D.1 Pioneer Road 

Construction N No permanent road construction.

E 15.09 III.D.2 

III.E.7

Timely Erosion 

Control Measures 

on Incomplete 

Road and Stream 

crossing Projects

B6.6 B6.66 

C6.6 C5.23# 

rd pkg

Y As directed by TSA and mitigation.

E 15.10 III.D.3,8

Control of Road 

Construction 

Excavation & Side 

cast Material

B6.222 rd pkg N

No new road construction. Straw bales 

would be used to control erosion for 

temporary construction, landings or other 

sediment disturbing activities. 

S 15.11 VII.A.

(all)

Servicing and 

Refueling of 

Equipment

B6.34 B6.341 

B6.342 Y

Servicing of equipment will be excluded 

from RHCAs and appropriate sites will be 

authorized by TSA with input from 

specialists as needed.

S 15.12 III.A.5 

IV.B.1

Control of 

Construction in 

Riparian Areas

B6.5 B6.61, 

C6.51, and 

C6.52. 124 

permit

Y

No permanent road construction. May come 

into play if stewardship contract includes 

culvert replacement. 
Appendix A – Best Management Practices

A -10 Lower West Fork Project Final EIS Class SWCP # State BMP Ref.

SWCP Title

TSC ProvisionApplicable? Y/N

Implementation/Planning Review

S 15.13 III.E.5

Controlling InChannel 

Excavation

C6.36, C6.52, 

and B6.5, 124 

prmt

Y

No permanent road construction. May come 

into play if stewardship contract includes 

culvert replacement. 

S 15.14 IV.A.(all

) V.C.5

Diversion of Flows 

Around 

Construction Sites

B6.5, 124 

permit Y

No permanent road construction. May come 

into play if stewardship contract includes 

culvert replacement. 

S 15.15

IV.A.(all

) V.B.2, 

V.C.4

Stream crossings 

on Temporary 

Roads

B5.1 B6.5 

C5.1 (124 

permit)

Y

This BMP would cover temporary road 

construction stream crossings. No temporary 

roads planned in RHCA’s

S 15.16

IV.A.(all

) 

V.C.(all)

Bridge and Culvert 

Installation 

(Disposition of 

Surplus Material 

and Protection of 

Fisheries)

 B6.5 Y Appropriate mitigation if culvert 

replacement required. 

E 15.18 III.D.6,8

Disposal of Rightof-Way and 

Roadside Debris

B6.5, Rd pkg Y Appropriate mitigation for temporary road 

construction, and pre-haul maintenance.

E 15.21 III.D.1 

III.E.1,2

Maintenance of 

Roads

C5.12 C5.31# 

C5.316# 

C5.314# 

C5.312# 

C5.41

Y

Engineering rep should be involved on 

newly graveled and upgraded roads to 

ensure protection of gravel surface during 

maintenance activities.

E 15.22 III.D.7

Road Surface 

Treatment to 

Prevent Loss of 

Materials

C5.31# (T-103)

C5.314# Y As directed by TSA.

E 15.23 III.D.6 

IV.B.1

Traffic Control 

During Wet 

Periods

B5.12, and 

C5.12 Y As directed by TSA and made necessary by 

weather conditions.

E 15.24 III.E.3,4 

VI.B.2

Snow Removal 

Controls C5.316# Y Refer to TSC and mitigation. Requires specific road numbers - 363. 

E 15.25 III.E.8 Obliteration of 

Temporary Roads C6.632# Y Refer also to mitigation in DEIS for temporary roads.
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-11

ClassSWCP #State BMP Ref.

SWCP Title

TSC ProvisionApplicable? Y/N

Implementation/Planning Review

Section 18 Fire Suppression and Fuels Management

A 18.02 IV.C.2 Formulation of Fire 

Prescriptions

Not in contract 

– USFS crews Y

Rx have been developed in IDT setting with 

specialist input and consideration of habitat 

type, existing vegetation, fuel loadings and 

position on landscape.

E 18.03 IV.C.8

Protection of Soil 

& Water from 

Prescribed Burning 

Effects 

Not in contract 

– USFS crews

Y

Burning should only occur during Rx 

window to meet prescribed fire intentions. 

See soil mitigations in DEIS.

E 18.04 None

Minimizing 

Watershed Impacts 

from Fire 

Suppression Efforts

Not in contract 

– USFS crews Y

Should a prescribed fire escape, resource 

advisor would advise suppression team of 

sensitive areas and resource concerns.

E 18.05 None

Stabilization of 

Fire Suppression 

Related Watershed 

Damage

Not in contract 

– USFS crews Y

This practice would be applied in the event a 

prescribed fire escaped containment. A 

resource advisor would inform the fire 

suppression team of sensitive areas and 

resource concerns.

SWCPS DESCRIPTIONS 

PRACTICE 11.07 - OIL AND HAZARDOUS SUBSTANCE SPILL CONTINGENCY

PRACTICE 15.11 - SERVICING AND REFUELING OF EQUIPMENT

OBJECTIVE: To minimize contamination of waters from accidental spills of fuels, lubricants, bitumen, raw 

sewage, wash water, and other harmful materials by prior planning and development of Spill Prevention 

Control and Countermeasure Plans.

EFFECTIVENESS: High based on reason, logic response , and observation.

IMPLEMENTATION: The Contracting Officer, Engineering Representative, or Timber Sale Administrator 

would designate the location, size, and allowable uses of service and refueling areas. They would also be 

aware of procedures to follow in case of a hazardous spill, as outlined in the Forest Hazardous Substance 

Spill Contingency Plan (SWCP 11.07). Contract provisions CT6.34 Sanitation and Servicing and BT6.341 

Prevention of Oil Spills are included in all timber sale contracts. BT6.341 requires the purchaser to prepare 

a spill prevention control and countermeasure plan, which shall meet applicable EPA requirements, 

including certification by a registered professional engineer. This requirement is implemented when the 

total oil or oil products storage exceeds 1,320 gallons, or when any single container exceeds 660 gallons.
Appendix A – Best Management Practices

A -12 Lower West Fork Project Final EIS 

PRACTICE 13.02 - SLOPE LIMITATIONS FOR TRACTOR OPERATION

PRACTICE 13.06 - SOIL MOISTURE LIMITATIONS FOR TRACTOR OPERATION

PRACTICE 14.02 – TIMBER HARVEST UNIT DESIGN

PRACTICE 14.07 – DETERMINING TRACTOR LOGGABLE GROUND

PRACTICE 14.08 – TRACTOR SKIDDING DESIGN

OBJECTIVE: To insure that timber harvest unit design would secure favorable conditions of water flow, 

maintain water quality and soil productivity, and reduce soil erosion and sedimentation during and 

following thinning and fuel reduction.

EXPLANATION: The recommendations in these practices are based on soil conditions and slope, which 

relate to erosion hazard. The objective of these practices is to minimize erosion by limiting tractor yarding 

to appropriate terrain and soils, and by designing skidding patterns to best fit the terrain. General slope 

limitations for tractor logging are 35% standard and 20% adverse (uphill). 

All tractor units would be logged using designated skid trails. Equipment would occasionally leave the 

trails to access trees or accomplish other activities.

Logging may occur in either winter or summer (subject to applicable timing restrictions required for other 

resources, such as wildlife). Winter ground-based yarding required in a portion of unit 1 under Alternative 

2. In all seasons, skid trails must be spaced about 120 feet apart. The goal is to occupy less than 15 percent 

of the harvest area, which includes soil disturbance from skid trails, temporary roads, and landings 

associated with either past activities or proposed activities.

All of the proposed units have less than 15 percent existing detrimental soil disturbance. Most of the 

existing soil disturbance is from old skid trails or roads, some of which can be reused. 

All existing roads and skid trails would be reused to the extent feasible unless doing so would adversely 

affect soil, water, or other resources. If roads or trails cannot be reused, their extent must be considered 

when laying out additional skid trails. 

To the extent possible, logging in summer would occur when the soils are drier than field capacity nearing 

the permanent wilting point, as determined by the hand feel method and observations of grasses and forbs,

which is described in the Project Record. 

Winter logging requires a combination of soil frost and snow depth sufficient to protect the soil from 

detrimental disturbance 

Timber Sale Administrators will monitor soil moisture conditions prior to allowing equipment to begin 

operations in summer and monitor snow and temperature conditions prior to winter logging. This 

monitoring must be documented in the Timber Sale Daily Report. 

All burn units would be ignited when burning conditions would maintain soil erosion and nutrient levels 

within the range of historic burns. 

If monitoring after project implementation indicates that detrimental soil disturbances for a given treatment 

unit exceed or equal 15 percent, then all or a portion of the following actions will be used to begin the 

restoration of soil quality. Restoration would occur on sites with a high amount of detrimentally disturbed 

ground such as designated skid trails and landings: 

Scarify heavily used skid trails and landings with the teeth on an excavator bucket to a depth of 2 to 4 

inches. Subsoiling with a grapple rake (SGR) or excavator bucket (SEB) may be necessary if it is 

determined that subsurface compaction is root limiting. In these cases, the subsoiling would decompact the 

skid trail to the appropriate depth to allow for productive vegetative growth.

Plant Montana-certified weed free native grasses on the scarified soils as recommended by the Forest 

Botanist. 
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-13

Plant native shrubs where needed to augment natural vegetation and scarification. 

The site condition will be used to determine which of the above mitigations would be used. These 

mitigations do not result in instant restoration of detrimentally disturbed soils; rather they begin the 

restoration process. 

All temporary roads (constructed and re-used existing templates) will be reclaimed after use, as soon as 

logistically practicable. The reclaiming of temporary roads will include removing any installed culverts or 

temporary bridges, re-contouring the entire road template to natural ground contour, and, to the extent 

feasible, placing the top soil back on the soil surface. Decompaction of the road bed will be completed on 

existing templates where topsoil materials are no longer available. Woody material should be placed on the 

recontoured/decompacted road where quantities in the immediate vicinity allow. The road reclamation will 

be completed with fertilization and seeding as specified by the Soil Scientist and Forest Botanist. 

EFFECTIVENESS: High - Experience of Bitterroot NF Soil Scientist and Botanist; based on reason, logic 

and observation.

IMPLEMENTATION: The following features would be designated on the Timber Sale Area Map:

Project Specific BMPs would be implemented primarily with the use of timber sale contract clause 

CT6.4,

PRACTICE 14.03 - USE OF SALE AREA MAPS FOR DESIGNATING SOIL AND WATER PROTECTION 

NEEDS

or other appropriate contract provisions. 

PRACTICE 14.16 – MEADOW PROTECTION DURING TIMBER HARVESTING

PRACTICE 14.17 STREAM COURSE PROTECTION (IMPLEMENTATION & ENFORCEMENT)

OBJECTIVE: To delineate the location of protection and special treatment areas and ensure their 

recognition, proper consideration, and protection during project activities.

EFFECTIVENESS: High; the hydrologist, fisheries biologist, and soil scientist review the timber ale area 

map; based on reason, logic, and observation.

IMPLEMENTATION: The following features would be designated on the Timber Sale Area Map:

Stream courses (perennial and intermittent) to be protected under contract clause 

Special treatment zones (STZS) as needed as per contract clause 

BT6.5

CT6.62 (site-specific wetland 

protection measures)

PRACTICE: 14.06 - RIPARIAN AREA DESIGNATION

.

OBJECTIVE: To minimize the adverse effects on Riparian Areas from adjacent logging and related land 

disturbance activities.

EFFECTIVENESS: High; local monitoring, and experience of the soil scientist, hydrologist, sale 

administrator and interdisciplinary team (ID Team) are that these requirements and criteria are highly 

effective in minimizing soil erosion.

IMPLEMENTATION: The Riparian Area requirements are identified during the environmental analysis by 

the ID Team. The timber sale project is designed to include site specific recommendations for the 

prevention of sedimentation and other stream damage from logging activities. The environmental analysis 

will provide for planning of harvests to insure long-term health and revegetation of the Riparian Areas, 

while meeting shading, debris recruitment, and other management objectives. As appropriate, monitoring 

and evaluation will be identified in the environmental analysis documentation. The Presale Forester is 

responsible for the inclusion of the Riparian Areas in the Timber Sale Contract and on the Sale Area Map. 
Appendix A – Best Management Practices

A -14 Lower West Fork Project Final EIS 

The certified Sale Administrator is responsible for contract compliance during harvest operations. Riparian 

area widths are determined by INFISH criteria and exceed MT DNRC requirements. 

PRACTICE 14.09 – SUSPENDED LOG YARDING, LANDING LOCATION AND DESIGN

OBJECTIVE: To protect the soil from excessive disturbance and accelerated erosion and to maintain the 

integrity of the Riparian Area and other sensitive watershed areas.

EFFECTIVENESS: High; Local monitoring, and experience of the soil scientist, hydrologist, sale 

administrator, and ID Team members indicate these requirements and criteria are highly effective in 

minimizing soil erosion.

IMPLEMENTATION: During the environmental analysis, the ID Team identifies areas where suspended log 

yarding is needed. The specific systems are included in the contract and designated on the Sale Area Map 

by the Presale Forester. The Timber Sale Administrator oversees the project operation using the guidelines 

and standards established in the timber sale contract with reference to the environmental analysis 

documentation.

Suspended log yarding includes all yarding systems in which logs are partially or wholly suspended off of 

the ground. These systems include high-lead, skyline, helicopter, and balloon yarders. The systems are 

used on steep or unstable slopes and in Riparian Areas where tractors cannot operate. All of these systems 

cause less soil disturbance because there is less contact between the soil and heavy machinery. In most 

cases, these systems require fewer roads because they have a longer “reach”. Fewer roads and less soil 

disturbance causes less soil and water resource impacts.

PRACTICE 14.10 - LOG LANDING LOCATION AND DESIGN

PRACTICE 14.11 - LOG LANDING EROSION PREVENTION AND CONTROL

PRACTICE 14.12 - EROSION PREVENTION AND CONTROL MEASURES DURING TIMBER SALE 

OPERATIONS 

PRACTICE 14.15 - EROSION CONTROL ON SKID TRAILS

OBJECTIVE: To protect water quality by minimizing erosion and subsequent sedimentation derived from 

log landings and skid trails.

EFFECTIVENESS: High; experience of the soil scientist, hydrologist, sale administrator, and ID Team 

indicate that these requirements and criteria are highly effective in minimizing soil erosion).

IMPLEMENTATION: Standard Timber Sale provision BT6.6 requires the purchaser to conduct operations 

in a reasonable fashion to minimize erosion. Additionally, specific erosion requirements would be spelled 

out in provisions such as CT6.4, CT6.6, CT6.601, CT6.62, and CT6.623. Project-specific BMPs would be 

implemented primarily through timber sale contract clause CT6.4, or other appropriate contract provisions. 

The following criteria would be used to control or minimize erosion from landings and skid trails:

1. Landings:

Maintain landings during periods of use in a manner that prevents debris and sediment from 

entering any streams.

Landings would drain in a direction and manner that would minimize erosion and preclude 

sediment delivery to any stream.

Standard timber sale contract provision B6.64 Landings requires that after landings have served the 

Purchaser's purpose, the Purchaser shall ditch or slope them to allow water to drain or spread. 

Landings would be seeded as needed with a mix approved by the Forest Botanist. 
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-15

2. Skid Trails:

Skid trails would be water-barred; the Timber Sale Administrator would designate the trail location 

and spacing (SWCP 15.25).

Skid trails likely to produce sediment would be covered with slash and/or seeded with a mix of 

seed and fertilizer specified in CT6.601

PRACTICE 14.18 - EROSION CONTROL STRUCTURE MAINTENANCE

OBJECTIVE: To ensure that constructed erosion control structures are stabilized and working effectively.

EFFECTIVENESS: High; experience of the soil scientist, sale administrator, and ID Team members is that 

the following requirement is highly effective in minimizing soil erosion.

IMPLEMENTATION: Timber Sale Contract provision, BT6.66, requires that during the period of the 

contract, the Purchaser shall provide maintenance of soil erosion control structures constructed by the 

Purchaser until they stabilize. The Forest Service may agree to perform such structure maintenance under 

BT4.228 Cooperative Deposits

PRACTICE 14.19 - ACCEPTANCE OF TIMBER SALE EROSION CONTROL MEASURES BEFORE SALE 

CLOSURE

, if requested by the Purchaser, subject to agreement on rates. Should the 

Purchaser fail to do seasonal maintenance work, the Forest Service may assume the responsibility and 

charge the Purchaser accordingly. The Timber Sale Administrator would ensure that erosion control 

structures are working effectively.

OBJECTIVE: To assure the adequacy of required erosion control work on timber sales.

EFFECTIVENESS: High; reasoned, logical response or observation.

IMPLEMENTATION: Timber Sale Contract provision BT6.36

PRACTICE 15.02 - GENERAL GUIDELINES FOR THE LOCATION AND DESIGN OF ROADS AND 

TRAILS

, requires that upon the Purchaser's written 

request and assurance that contract work has been completed; the Forest Service shall perform an 

acceptance inspection. For erosion control work, "acceptable" means only minor deviation from 

established standards, provided no major or lasting impact is caused to soil and water resources. The 

Timber Sale Administrator would not accept as complete, any erosion control work that does not meet this 

criteria.

OBJECTIVE: To locate and design roads and trails with minimal soil and water resource impact while 

considering all design criteria.

EXPLANATION: Several considerations must be incorporated into the location and design of roads and 

trails. These factors directly affect protection of water quality, soil, and other resource values. The 

following coordination instructions apply to all transportation activities:

A. Area Transportation Analysis and project planning will be completed using an interdisciplinary 

process, and the appropriate NEPA document will be prepared and tiered to the Forest Plan. 

Area Transportation analysis is an extremely effective tool to reduce overall road mileages and 

minimize potential resource impacts.

B. Location, design, and construction activities shall utilize appropriate technical resource staffs, 

when needed, to evaluate effects of transportation development and operations, and 

recommend mitigating measures to minimize adverse impacts.
Appendix A – Best Management Practices

A -16 Lower West Fork Project Final EIS 

C. Roads and trails will be located and designed to facilitate completion of the transportation 

system, serve specific resource management needs, fit the terrain, and minimize damage to 

improvements and resources. Fragile, unstable, sensitive, or special areas should be avoided.

D. Roads and trails should be designed based on traffic and safety requirements of anticipated use 

and to meet the overall transportation plan. The design shall incorporate features to prevent or 

minimize soil movement and sedimentation as well as undue disruption of water flow.

E. Stream crossing structures shall be designed to provide the most efficient drainage facility 

consistent with resource protections, importance of the road, legal obligations, and total costs. 

The design may involve a hydrologic analysis to determine runoff rates and volumes, flood 

conditions, velocities, scour, open channel shapes, approach topography, materials-foundation 

condition, and fish passage, as required. An economic comparison of various flood frequencies 

versus structure sizes and types is also considered.

F. Locate and design roads and trails to drain naturally by appropriate use of out-sloping or insloping with cross drainage and grade changes, where possible. Relief culverts and roadside 

ditches will be designed whenever reliance upon natural drainage would not protect the 

running surface, excavation, or embankment. Road and trail drainage should be channeled to 

effective buffer areas to maximize sediment deposition prior to entry into live water.

EFFECTIVENESS: High for new permanent or temporary roads; reasoned, logical response, or observation.

IMPLEMENTATION: During the environmental analysis, the ID team ensured that management needs, 

objectives, requirements, and controls are incorporated in the location and design of roads and trails. 

Mitigation measures needed to protect soil and water resources were identified in the NEPA process. 

Contract provisions will be prepared that meet the soil and water resource protection requirements.

PRACTICE 15.03 - ROAD AND TRAIL EROSION CONTROL PLAN

OBJECTIVE: To prevent, limit, and mitigate erosion, sedimentation, and resulting water quality 

degradation prior to the initiation of construction and maintenance activities through effective contract 

administration during construction and timely implementation of erosion control practices.

EXPLANATION: Land disturbing activities usually result in at least short-term erosion. Poorly designed, 

located, constructed, and maintained roads and trails are usually responsible for the majority of stream 

sedimentation problems associated with forest management practices. By effectively planning for erosion 

control, sedimentation can be minimized.

Roads and trails require a variety of erosion control measures. Many erosion control practices not only 

protect water quality but also maintain road prism integrity, reduce maintenance costs, and improve traffic 

characteristics. The location of the road or trail with respect to streams, beneficial uses of that water, soil, 

and geologic information and other site factors govern the degree of stabilization required. Stabilization 

usually includes a combination of practices that promotes the re-establishment of vegetation on exposed 

slopes, provides physical protection to exposed surfaces, prevents the downslope movement of soil, or 

controls road drainage.

Since a newly constructed road is most susceptible to erosion from seasonal precipitation, the timing of 

erosion control practices is of primary concern. Those practices that can be accomplished concurrent with 

road construction shall be favored as a means of immediate protection of the water resource

EFFECTIVENESS: Moderate – High; reason, logical response, and observation).

IMPLEMENTATION: Erosion control objectives and detailed mitigation measures are developed using an 

interdisciplinary approach during the environmental analysis. The contract specifications and provisions 

for the road or trail shall reflect these measures and objectives. When standard specifications do not 

provide the degree of mitigation required, the ID team will develop special project specifications.
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-17

Prior to the start of construction, the Purchaser shall submit a schedule for proposed erosion control work 

as required in the timber sale contract standard specifications. The schedule shall include all erosion 

control items identified in the specifications. The schedule shall consider erosion control work necessary 

for all phases of the project. The Purchaser's construction schedule and plan of operation will be reviewed 

in conjunction with the erosion control plan to insure their compatibility before any schedules are 

approved. No work will be permitted on the project until the Contracting Officer has approved all 

schedules.

The Contracting Officer or Engineering Representative shall ensure that erosion control measures are 

implemented according to the approved schedule and are completed in an acceptable fashion. Field 

reviews and on-site inspection by the Line Officer and/or Forest Engineer will identify any additional 

erosion control measures required to protect the streams that were not recognized during planning or 

design. Necessary correction measures shall be implemented immediately through normal administrative 

channels.

The following items may be considered as erosion control measures when constructed in a timely manner. 

To maximize effectiveness, erosion control measures must be in place and functional prior to seasonal 

precipitation or runoff.

A. Measures to reestablish vegetation on exposed soils: This is usually accomplished by 

seeding suitable grass and legume species in conjunction with mulching and fertilization. In 

some situations, treatments may include tree seedling planting or sprigging of other woody 

species.

B. Measures which physically protect the soil surface from detachment or modify the 

topography to minimize erosion: These treatments may include the use of dust oil or gravel 

on the road travelway and ditches and the use of mulches, riprap, erosion mats, and terracing 

on cuts, fills, and ditches. Temporary waterbars on unfinished roads and trails can effectively 

reduce sedimentation.

C. Measures which physically inhabit the downslope movement of sediments to streams: 

These measures may include the use of slash filter windrows on or below the fill slopes, baled 

straw in ditches or below fill slopes, catch basins at culvert inlets, and sediment basin slash 

filter windrows may be utilized in live water drainages where fish passage is not required and 

where peak flows are low.

D. Measures that reduce the amount of soil disturbance in or near streams: These measures 

may include dewatering culvert installation or other construction sites, and immediate 

placement of permanent culverts during road pioneering. Temporary pipes should not be 

allowed unless positive control of sedimentation can be accomplished during installation, use, 

and removal.

E. Measures that control the concentration and flow of surface and subsurface water: These 

may include insloping, outsloping, ditches, cross drains, under drains, trenches, and so forth.

PRACTICE 15.06 - MITIGATION OF SURFACE EROSION AND STABILIZATION OF SLOPES

PRACTICE 13.04 - REVEGETATION OF SURFACE DISTURBED AREAS

OBJECTIVE: To protect soil productivity and water quality at culvert removal and culvert upgrade sites by 

minimizing soil erosion.

EXPLANATION: This practice is used to stabilize disturbed area surfaces with vegetation. The type of 

vegetation to use is determined by evaluating soil fertility and water holding capacity, slope, aspect, 

landtype characteristics, climate, vegetation species characteristics, and project objectives. Based on field 

observations and interpretations, the ID Team selects the type of vegetation that meets many or most of the 

management objectives for the area; range, wildlife, timber, fuels, minerals, and aesthetics. Grass or 
Appendix A – Best Management Practices

A -18 Lower West Fork Project Final EIS 

browse species (shrubs) may be seeded or planted between recently planted trees for erosion prevention, 

wildlife habitat enhancement, or other management needs.

EFFECTIVENESS: Moderate; reason, logical response, and observation

IMPLEMENTATION: The identification of disturbed areas and vegetation species mix are determined 

during the NEPA process. The responsible Line Officer assigns specific individuals to execute the project. 

Projects are subsequently monitored to assess the revegetation effectiveness, and need for follow-up action.

PRACTICE 13.07 – PESTICIDE USE PLANNING

PRACTICE 13.08 – APPLY PESTICIDES ACCORDING TO LABEL AND EPA REGISTRATION 

DIRECTIONS

PRACTICE 13.09 – PESTICIDE APPLICATION MONITORING AND EVALUATION

PRACTICE 13.10 – PESTICIDE SPILL CONTINGENCY PLANNING

PRACTICE 13.11 – CLEANING AND DISPOSAL OF PESTICIDE CONTAINERS AND EQUIPMENT

PRACTICE 13.12 – PROTECTION OF WATER, WETLANDS, AND RIPARIAN AREAS DURING

PESTICIDE SPRAYING

PRACTICE 13.13 – CONTROLLING PESTICIDE DRIFT DURING SPRAY APPLICATION

PRACTICE: 13.07 – PESTICIDE USE PLANNING

OBJECTIVE: To incorporate water quality and hydrologic considerations into the Pesticide Use Planning 

Process.

EXPLANATION: The pesticide use planning process will be used to identify problem areas and the 

objectives of the project, establish the administrative controls, identify treatments and preventive measures, 

and incorporate the hydrologic considerations contained in SWCP 13.08 through 13.13. The NEPA 

process addresses these considerations in terms of impacts, mitigation measures, and alternative treatment 

measures. Project work and safety plans specify management direction.

Factors considered in pesticide selection are: purpose of the project, application methods available, target 

species, timing of treatment, pest location, size of treatment area, and need for repeated treatment. 

Practicability of application considers: registration restrictions, form and method of application, 

topographic relief and areas to be avoided, and social acceptance of the project. The degree of risk 

considers: hazard to humans, method of application, transportation and handling hazards, carriers needed, 

and chemical persistence.

EFFECTIVENESS: High; reason, logical response, and observation

IMPLEMENTATION: The interdisciplinary team evaluates the project in terms of potential site response, 

potential social and environmental impacts, mitigating measures needed to protect water quality, and the 

need and intensity of monitoring and evaluation. The responsible Line Officer then prepares the necessary 

NEPA documentation, Project Plan and Safety Plan. Depending on the pesticide use, (FSM 2151.04) the 

Forest pesticide-use coordinator or Integrated Pest Management Working Group or regional IP-MWG 

reviews the documents along with the Pesticide-use Proposal, form FS-2100-2, and makes

recommendations for or against approval of the project.

REFERENCES: NFMA; NEPA; FSM 2150 and 2323; State Hazardous Waste Management Plans; see 

references in “Best Management Practices” Definition 05—2 and 3.

PRACTICE 13.08 – APPLY PESTICIDES ACCORDING TO LABEL AND EPA REGISTRATION 

DIRECTIONS

OBJECTIVE: To avoid water contamination by complying with all label instructions and restrictions.
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-19

EXPLANATION: Label directions for each pesticide are detailed and specific, and include legal 

requirements to use.

EFFECTIVENESS: High; reason and logical response.

IMPLEMENTATION: Constraints identified on the label and other legal requirements of application are 

incorporated into project plans and contracts. Responsibility for ensuring that label directions and other 

applicable requirement are followed rests with the Forest Supervisor or designate such as the Forest 

Pesticide Use Coordinator. For contracted projects, it is the responsibility of the Contracting Officer to 

ensure that label directions and all other requirements are followed.

REFERENCES: FSM 2150; Best Management Practice Definition (05—2 and 3).

PRACTICE 13.09 – PESTICIDE APPLICATION MONITORING AND EVALUATION

OBJECTIVE: To determine and document that pesticides have been applied safely and to provide an early 

warning for any contamination of water or non-target areas or resources.

EXPLANATION: This practice provides feedback on the placement accuracy, application amount, and any 

water contamination that might occur from pesticide use to minimize or eliminate hazards to non-target 

areas or resources. Monitoring and evaluation methods include spray cards, dye tracing, and direct 

measurement of pesticide in or near water. Type of pesticide, equipment, application difficulty, public 

concern, beneficial uses, monitoring difficulty, availability of competent laboratory analysis and applicable 

federal, State, and local laws and regulations are factors considered when determining the monitoring and 

evaluation needs.

EFFECTIVENESS: High; reasoned and logical response.

IMPLEMENTATION: The monitoring and evaluation of pesticide application is a component of SWCP 

11.02. The need for a monitoring plan is identified during the Pesticide Use Planning Process/NEPA 

process. If determined necessary, this monitoring and evaluation plan will consider the same items as in 

SWCP 11.02. A technical staff familiar in pesticide monitoring will evaluate and interpret the monitoring 

results in terms of compliance, State water quality standards, and adequacy of project specifications.

REFERENCES: FSM 2150; Best Management Practice Definition (05—2 and 3).

PRACTICE 13.10 – PESTICIDE SPILL CONTINGENCY PLANNING

OBJECTIVE: To reduce contamination of water from accidental pesticide spills.

EXPLANATION: A contingency plan that contains a predetermined organization and immediate actions to 

be implemented in the event of a hazardous substance spill will be prepared. The plan lists notification 

requirements, time requirements for notification, how spill will be handled, and who will be responsible for 

clean-up. Factors considered for each spill are: specific substance spilled, quantity, toxicity, proximity of 

spill to waters, and the hazard to life, property, and the environment.

EFFECTIVENESS: High; reasoned, logical response, and observation.

IMPLEMENTATION: The Pesticide Spill Contingency Plan will be incorporated into the Project Safety 

Plan. The NEPA process will provide the means for including public and other agency involvement in plan 

preparation. The plan will list the responsible authorities.

REFERENCES: SWCP 11.07; Pesticide Storage, Transportation, Spills, and Disposal Handbook 

(FSH 2109.12); FSM 6740, 7442, 7443, and 7460; Oil and Hazardous Substances Pollution contingency 

Plan for EPA Region 8 and 10, 7/26/85; R1 and R4 Emergency and Disaster Plan; Best Management 

Practice Definition (05—2 and 3).
Appendix A – Best Management Practices

A -20 Lower West Fork Project Final EIS 

PRACTICE 13.11 – CLEANING AND DISPOSAL OF PESTICIDE CONTAINERS AND EQUIPMENT

OBJECTIVE: To prevent water contamination and risk to humans from cleaning and disposal of pesticide 

containers.

EXPLANATION: The cleaning and disposal of pesticide containers and equipment must be done in 

accordance with Federal, State, and local laws, regulations, and directives, and in a manner which will 

safeguard public health, the beneficial uses of water, aquatic organisms, and wildlife. Containers are rinsed 

three times, the rinse water applied on the project area as soon as practical, and the containers taken to the 

designated disposal site. Application equipment is also rinsed and rinse water applied to the project site 

before the equipment is moved from the project area.

EFFECTIVENESS: Moderate; reason, logical response, and observation

IMPLEMENTATION: The Forest or District Pesticide Use Coordinator will locate proper rinsing and 

disposal sites, and will arrange for container disposal in an approved disposal site when pesticide is applied 

by Forest Service personnel. When the pesticide is applied by a contractor, the contractor is responsible for 

proper clean-up and container disposal in accordance with label directions and Federal, State, and local 

laws.

REFERENCES: SWCP 11.07; Pesticide Storage, Transportation, Spills, and Disposal Handbook 

(FSH 2109.12); FSM 6740, 7442, 7443, and 7460; Oil and Hazardous Substances Pollution contingency 

Plan for EPA Region 8 and 10, 7/26/85; R1 and R4 Emergency and Disaster Plan; Best Management 

Practice Definition (05—2 and 3).

PRACTICE 13.12 – PROTECTION OF WATER, WETLANDS, AND RIPARIAN AREAS DURING

PESTICIDE SPRAYING

OBJECTIVE: To minimize the risk of a pesticide entering surface or subsurface waters or affecting riparian 

areas, wetlands, or other non-target areas.

EXPLANATION: When applying pesticides, an untreated buffer strip will be left alongside surface waters, 

wetlands, and riparian areas. Factors considered in establishing buffer strip widths beyond minimums 

established by FSM and NEPA documents are: beneficial water uses, adjacent land use, rainfall, 

temperature, wind speed, wind direction, terrain, slope, soils and geology, vegetative type, and aquatic life. 

Other considerations include: persistence mobility, toxicity, and formulation of the pesticide, method of 

application, equipment used, spray pattern, droplet size, application height, and application pattern.

EFFECTIVENESS: High; reasoned, logical response, observation

IMPLEMENTATION: The interdisciplinary team and the Forest Pesticide Use Coordinator will identify and 

map protected areas during the NEPA process. Protection of untreated areas is the responsibility of the 

project supervisor for Forest Service applications and the Contracting Officer for contracted projects. The 

certified commercial applicators are briefed about location of protected areas. These areas are flagged or 

otherwise marked when necessary to aid in boundary identification.

REFERENCES: FSM 2526, 2527, 2245, and 2150; see references in Best Management Practice (05—2 

and 3).

PRACTICE 13.13 – CONTROLLING PESTICIDE DRIFT DURING SPRAY APPLICATION

OBJECTIVE: To minimize the risk of pesticide contaminating non-target areas.

EXPLANATION: Pesticide spray applications will be accomplished according to a prescription that 

specifies the following: areas to be left untreated, buffer areas, type of spray and associated materials, 

equipment and method to be used, droplet size, spray height, application pattern, flow rate, terrain, and 
Appendix A – Best Management Practices

Lower West Fork Project Final EIS A-21

weather. Hand spraying, with less associated risk, will have fewer application restrictions for drift than 

aerial spraying.

EFFECTIVENESS: High; reasoned, logical response, and observation

IMPLEMENTATION: The ID Team and the Forest or District Pesticide Use Coordinator prepare the 

prescription during the NEPA process. The Line Officer is responsible for designating a project supervisor 

who is responsible for ensuring the prescription is followed during application and for terminating 

application if the standards are exceeded.

REFERENCES: FSM 2150 and 2245; SWCP 13.12; Best Management Practice Definition (05—2 and 3).

Other BMPs

• A spill cleanup kit will be available whenever pesticides (herbicides) are transported or stored.

• A spill contingency plan will be developed prior to all herbicide applications. Individuals involved 

in herbicide handling or application will be instructed on the spill contingency plan and spill 

control, containment, and cleanup process.

• Herbicide applications will only treat the minimum area necessary for control of noxious weeds.

• No spraying will occur when wind velocity exceeds 6 miles per hour or as specified on the label.

• Do not spray if precipitation is occurring or is imminent.

• Do not spray if air turbulence is sufficient to affect the normal spray pattern.

For additional information on SWCP’s, including Objectives and Effectiveness, refer to Forest Service 

Handbook 2509.22 on file at the Supervisor’s Office or the West Fork Ranger Station.
Appendix C - Literature Cited

Lower West Fork Project Final EIS - C-1

APPENDIX C

LITERATURE CITED

Adams P.A. and Froehlich H.A. (1984). Compaction of Forest Soils. Pacific Northwest. Extension 

Publication PNW 217. Pacific Northwest Experimental Station, Portland, Oregon, USA. [0688]

Adams, S.B., D.A. Schmetterling and M.K. Young. 2005. Instream movements by boreal toads (Bufo 

boreas boreas). Herpetological Review 36:27-33. [0623]

Agee, James K. 1993. Fire Ecology of Pacific Northwest Forests, Chapters 2, 3, 10, and 11. Island Press, 

Washington D.C. pp. 33-52. [0608]

Agee, J.K. and C. N. Skinner. 2005. Basic principles of forest fuel reduction treatments. Forest Ecology 

and Mgmt. 211 (2005) 83-96. [0300]

Air Sciences Inc, 2003. Users Guide: Smoke Impact Spreadsheet (SIS) Model. Prepared for USDA Forest 

Service, Northern Region, Project No. 189-1. June. 31pp. [0098] 

Available online at: http://www.airsci.com.

Alexander, M.E.; and Hawksworth, F.G.1975. Wildland fires and dwarf mistletoes: a literature review of 

ecology and prescribed burning. USDA. Forest Service. Gen. Tech. Rep. RM-14. Rocky MT. For. 

And Range Exp. Stn. Fort Collins, CO. 12 p. [0878]

Amman, G.D., M.D. McGregor, D.B. Cahill and W.H. Klein. 1977. Guidelines for reducing losses of 

lodgepole pine to the mountain pine beetle in unmanaged stand in the Rocky Mountains. Gen. Tech. 

Rep. INT-36. Ogden, UT: USDA, Forest Service, Intermountain Forest & Range Exp. Station. 19p. 

[0263]

Amman, G. D., Logan, J. A. 1998. Silviculture Control of Mountain Pine Beetle: Prescriptions and the 

Influence of Microclimate. American Entomologist, Fall 1998. 12 p. [0316]

Anderson, L., C.E. Carlson and R.H. Wakimoto. 1987. Forest fire frequency and western spruce budworm 

outbreaks in western Montana. Forest Ecology Management. 22: 251-260. [0881]

Andrews, Patricia L.; Carolyn H. Chase. 1989. BEHAVE: Fire behavior prediction and Fuel Modeling 

System—BURN subsystem, Part 2. Gen. Tech. Rpt. INT-260. Ogden, UT: USDA Forest Service, 

Intermountain Research Station. 93 p. [0609]

Andrus C.W. and H.A. Froehlich . 1983. An evaluation of four implements used to till compacted forest 

soils in the Pacific Northwest. Research Bulletin 45. Forest Research Lab, College of Forestry, Oregon 

State University, Corvallis, OR. [0868]

Applegate, Vick; Hillis, Mike; Slaughter, Steve; Harrington, Michael G.; Smith, Helen 2001. Simulating 

historical disturbance regimes and stand structures in old-forest ponderosa pine/Douglas-fir forests. 

In: Barras, Stanley J., ed. Proceedings: National silvicultural workshop; 1999 October 5-7; Kalispell, 

MT. Proceedings RMRS-P-19. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky 

Mountain Research Station. p. 32-39. [0890]

Archer, E.J., A. Birnie, B. Bouwes, J. Heitke, and G. Kliewer. 2006. Effectiveness monitoring program 

for streams and riparian areas within the Upper Columbia River basin. Region 1 – Annual Report, 

2006. Fish & Aquatic Ecology Unit, Logan, UT. http://www.fs.fed.us/biology/fishecology/emp 

[0916]
Appendix C - Literature Cited

C-2 Lower West Fork Project Final EIS

Arnett, E.B., B. Altman, and W.P. Erickson. 1997a. Effects of salvage logging on neotropical migratory 

landbirds in lodgepole pine forests of central Oregon: 1997 preliminary results. Unpubl. report to the 

Weyerhaeuser Co., Springfield, OR. [0695]

Arnett, E.B., B. Altman, and W.P. Erickson. 1997b. Relationships between salvage logging and forest 

avifauna in lodgepole pine forests of the central Oregon Pumice Zone. Unpubl. 1996 annual report to 

the Weyerhaeuser Co., Springfield, OR. [0625]

Arno, S. F. 1976. The historical role of fire on the Bitterroot National Forest. Ogden, UT: USDA Forest 

Service, Intermountain Forest and Range Experiment Station. Res. Pap. [0047]

Arno, S.F. 1980. Forest fire history in the Northern Rockies. Journal of Forestry 78(8): 460-465. [0883]

Arno, S. F. 1988. Fire ecology and its management implications in ponderosa pine forests. IN: Ponderosa 

Pine: The Species and its Management – Symposium Proceedings. Eds. D.M. Baumgartner and J.E. 

Lotan, Spokane, WA. September 29-October 1, 1987. Published by Washington State Univ, Pullman, 

WA. 1988. Pages 133-140. [1022]

Arno, S.F.; Sneck, K.M. 1977. A method for determining fire history in coniferous forests of the Mountain 

West. Gen. Tech. Rep. INT-42. Odge, UT USDA, Forest Service, Intermountain Forest. and Range 

Exp. Station. 28p. [0882]

Arno, S.F. and T. D. Peterson. 1983. Variation in estimates of fire intervals: a closer look at fire history on 

the Bitterroot National Forest. Research paper INT-301. Ogden, UT: USDA, Forest Service, 

Intermountain Forest. and Range Exp. Station. [0196]

Arno, S.F.; Simmerman, D.G.; Keane, R.E. 1985. Forest Succession on four habitat types in western 

Montana. Gen. Tech. Rep. INT-177. Ogden, UT: U.S.Department of Agriculture, Forest Service, 

Intermountain Research Station. 74p. [0195]

Arno, Stephen F. and George E.Gruell, 1986. Douglas-fir Encroachment into Mountain Grasslands in 

Southwestern Montana. J. of Range Management, 39(3). [0373]

Arno, S F.; Harrington, M.G.; Fiedler, C.E.; Carlson, C.E. 1995. Restoring fire dependent ponderosa pine 

forest in Western Montana. Pacific Northwest Reports. Restoration & Management Notes. Summer 

13(1). 32-36. [0365]

Arno, S F.; Scott, J.H. and Hartwell, M.G. 1995. Age-class structure of old growth ponderosa 

pine/Douglas-fir stands and its relationship to fire history. Res. Pap. INT-RP-481. Ogden, UT: U.S. 

Dept. of Agriculture, Forest Service, Intermountain Research Station. 25 p. [0703]

Arno, S.F.; Smith, H.Y.; Krebs, M.A. 1997. Old growth ponderosa pine and western larch stand structure: 

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Appendix C - Literature Cited

C-26 Lower West Fork Project Final EIS

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Lower West Fork Project Final EIS - C-27

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Appendix D - Glossary

Lower West Fork Project Final EIS D-1

APPENDIX D

GLOSSARY

ACTIVITY: A course of action or treatment that is undertaken to directly or indirectly produce, enhance, 

or maintain forest and range land outputs or achieve administrative or environmental objectives.

ACTIVITY AREA: Area within the project area where activities are proposed.

ACTIVITY FUELS: Fuels generated as the result of a timber sale or other vegetation treatments.

AERIAL FUELS: All live and dead vegetation located in the forest canopy or above the surface fuels, 

including tree branches and crowns, snags, moss and high brush. 

AFFECTED ENVIRONMENT: The biological, physical, and human settings changed by the 

alternatives.

AGE CLASS: - An interval, commonly 10 years, into which the age range of trees or vegetation is divided 

into for classification. May also refer to general diameter classes and displayed as seedling, sapling, pole, 

mature etc. 

AGGRADATION (DEPOSITION): When more sediment enters a reach than leaves it, there is a buildup 

of sediment. This is called aggradation or deposition.

AIR QUALITY: Refers to standards for various classes of land as designated by the Clean Air Act, P.L. 

88-206: Jan. 1978.

AIRBORNE PARTICULATE: Total suspended particulate matter found in the atmosphere as solid 

particles or liquid droplets. Particulates include: windblown dust, emissions from industrial processes, 

smoke from the burning of wood and coal, and the exhaust of motor vehicles.

AIRSHED: Geographical areas identified by the Montana/Idaho Airshed Group with similar topography 

and weather patterns.

ALL TERRAIN VEHICLE (ATV): A type of off-highway vehicle that travels on three or more lowpressure tires; has handle-bar steering; is less than or equal to 50 inches in width; and has a seat designed to 

be straddled by the operator.

ALTERNATIVE: Management options for responding to the purpose and need for action and/or issues.

ANALYSIS AREA: The geographic area defining the scope of analysis for a particular resource. This 

area may be larger than the project area when effects have the potential to extend beyond the boundaries of 

the proposed action.

APPEAL: A request by any party dissatisfied with a decision of a Forest Officer to have that decision 

reviewed at a higher organizational level within the Forest Service and, where appropriate, by the Secretary 

of Agriculture.

APPROPRIATED FUNDS: Monies allotted or budgeted for departments to fund the job activities taking 

place for the fiscal year.

AQUATIC SYSTEMS: Biological and physical attributes and their interaction related to water.

ASPECT: - The direction towards which a slope faces, expressed in cardinal directions such as north, east, 

south, west. 

AVAILABLE FUEL: The portion of the total fuel that actually burns. 

BACKING FIRE: A slowly advancing fire that is burning into or against the wind or downslope. See head 

fire. 

BASAL AREA: The area of the cross-section of a tree stem measured at 4.5 ft. above the ground. Basal 

area can be used to measure how much of a site is occupied by trees. Stand basal area can be described by 

the total basal area per unit area.
Appendix D - Glossary

D- 2 Lower West Fork Project Final EIS 

BENEFICIAL USES: Attributes that are considered useful products of the resource. They may include 

(but are not limited to): recreation, production of salmonid fishes, drinking water, power generation, and 

irrigation.

BEST MANAGEMENT PRACTICES (BMP): A set of practices which, when applied during 

implementation of a project, ensures that water-related beneficial uses are protected and that State water 

quality standards are met.

BIG GAME: Those species of large mammals normally managed as a sport hunting resource.

BIODIVERSITY: Biodiversity is the variety of life in an area, including all the processes of life. Included 

in this definition is genetic diversity in species; species richness; variety, patterns, and abundance of species 

communities and ecosystems at large geographical scales; and the processes whereby species interact.

BIOLOGICAL ASSESSMENT: Information (document) prepared by or under the direction of the federal 

agency concerning listed and proposed threatened and endangered species and proposed critical habitat that 

may be present in the action area and the evaluation of potential effects of the action on such species and 

habitats.

BIOLOGICAL EVALUATION: A documented Forest Service review of programs or activities in 

sufficient detail to determine how an action or proposed action may affect any sensitive species.

BIOMASS: The sum total of living plants and animals above and below ground.

BLOWDOWN: Trees that have been uprooted by the force of wind. 

BOARD FOOT (BF): A unit of measurement equal to an unfinished board one square foot by one inch 

thick. Timber volumes are often expressed in terms of thousands of board feet (MBF) or millions of board 

feet (MMBF).

BOGS: Perennially saturated areas that usually have wetland and riparian plants surrounding them.

BOLE: The trunk or main stem of the above ground part of a tree.

BROADCAST BURN: Intentional burning within well defined boundaries for reduction of fuel hazard, as 

a resource management treatment, or both. Also see Prescribed Burning.

BULK DENSITY: The mass of dry soil per unit volume, corrected for weight and volume of coarse 

fragments greater than 2mm in diameter. 

BURN INTENSITY: See Fire Intensity.

BURN SEVERITY: See Fire Severity; Vegetation Impacts.

BURNING PERIOD: That part of each 24-hour period when fires will spread most rapidly. Most 

commonly 10:00 am to 4:00 pm.

CANDIDATE SPECIES: Species identified by the United States Fish and Wildlife Service (USFWS) or 

the National Marine Fisheries Service (NMFS), which are considered to be candidates for listing under the 

Endangered Species Act.

CANOPY: The more or less contiguous cover of branches and foliage formed collectively by the crowns 

of adjacent trees. Layers of the canopy may be distinguished with each layer representing one storey. For 

example, vegetation may be called single storied, two storied or multi storied. 

CANOPY CLOSURE: The progressive reduction of space between tree crowns as they spread laterally; a 

measure of the percent of potential open space occupied by the collective tree crowns in a stand.

CANOPY FUELS: The live and dead foliage, live and dead branches, and lichen of trees and tall shrubs 

that lie above the surface fuels.

CAVITY: Hollows, which are excavated in trees by birds, used for roosting and reproduction by many 

birds and mammals.

CAVITY HABITAT: Standing dead trees, broken-topped live trees, and down logs used by wildlife 

species that excavate and/or occupy cavities in these trees. 
Appendix D - Glossary

Lower West Fork Project Final EIS D-3

CHAIN: A non-metric measure of distance common to land surveying, forestry and fire management. One 

chain equals 66 feet. 

CLEARCUT HARVEST: Removal of the entire stand in one cutting with reproduction obtained either by 

planting or natural seeding from adjacent stands. 

CLOSED CANOPY: The condition that exists when the canopy created by trees or shrubs or both is dense 

enough to exclude most of the direct sunlight from the forest floor.

CLOSED ROAD: A national forest road or segment which is restricted from certain types of use during 

certain seasons of the year. The prohibited use and the time period of closure must be specified. The 

closure is legal when the Forest Supervisor has issued an order and posted it in accordance with Chapter 36 

of the CFR section 261.

COARSE WOODY DEBRIS: Sound and rotting dead woody plant material, standing or fallen, generally 

greater than 3 inches in diameter. It provides habitat for wildlife and plants and is a source of nutrients and 

structures for soil protection and development.

CODE OF FEDERAL REGULATIONS (CFR): The official, legal tabulation, or regulations directing 

federal government activities. 

COMMUNITY: A group of one or more populations of plants and animals in a common spatial 

arrangement; an ecological term used in a broad sense to include groups of various sizes and degrees of 

integration. 

COMPACTION: A physical change in soil properties from compression, vibration, or shearing that 

increases soil bulk density and decreases porosity, air exchange, root penetration, infiltration, and 

permeability. 

CONTAIN A FIRE: To take suppression action, as needed, which can be reasonably be expected to check 

the fire's spread under prevailing conditions. (Obsolete terminology) 

CONTROLLED BURNING: See Prescribed Burning. 

CONTROL LINE (Fire Line): An inclusive term for all constructed or natural fire barriers and treated fire 

edge used to control a fire. 

CONIFER: Any of a group of needle and cone-bearing evergreen trees, typically referring to 

gymnosperms.

CONVECTION COLUMN: The thermally produced, ascending column of gases, smoke, and debris 

produced by a fire. 

CORRIDORS: An area through which species can move from one place to another over time in response 

to changes in environment or as a natural part of their life history. 

COST: The negative or adverse effects or expenditures resulting from an action. Costs may be monetary, 

social, physical, or environmental in nature.

COUNCIL OF ENVIRONMENTAL QUALITY (CEQ): An advisory council to the President 

established by the National Environmental Policy Act of 1969. It reviews federal programs for their affect 

on the environment, conducts environmental studies, and advises the President on environmental matters.

COVER: Vegetation used by wildlife for protection from predators, breeding, and rearing of young (hiding 

cover), or to ameliorate conditions of weather (thermal cover).

CROWN FIRE: A fire that advances from the top to top of trees or shrubs more or less independently of 

the surface fire. Sometimes crown fires are classed as either dependent or independent, to distinguish the 

degree of independence from the surface fire's influence. See crown out. 

CULTURAL RESOURCES: The physical remains of human activity (e.g., artifacts, ruins, burial mounds, 

petroglyphs, etc.) having scientific, prehistoric, or social values.
Appendix D - Glossary

D- 4 Lower West Fork Project Final EIS 

CUMULATIVE EFFECT: The impact on the environment which results from the incremental impact of 

past, present, and reasonably foreseeable actions. Cumulative impacts can also result from individually 

minor but collectively significant actions over a period of time. 

DECADENT: Deteriorating; when used in reference to the conditions of groups of trees, there are 

inferences of the loss of trees from the overstory and of the presence of disease, or indications of loss of 

vigor in dominant trees.

DECIDING OFFICER: The Forest Service employee who has the authority to select and/or carry out a 

specific planning action. May also be referred to as the “Responsible Official”.

DECOMMISSION: To remove those elements of a road or buildings that reroute hillslope drainage and 

present slope stability hazards – synonym hydrologic obliteration.

DEGRADATION: This occurs when a stream has excess energy and more sediment leaves a reach than 

enters it. This is associated with channel scouring. 

DENNING SITE: A place of shelter for an animal; also where an animal gives birth and raises young.

DETRIMENTAL SOIL CONDITION: The condition where established soils quality standards are not 

met and the result is a significant change in soil quality.

DESIGNATED ROADS AND TRAILS: Specific roads and trails identified by the agencies where some 

type of motorized vehicle use is appropriate and allowed either yearlong or seasonally.

DESIRED NON-NATIVE SPECIES: Those species of plants or animals, that are not indigenous to an 

area but which represent an important social or economic benefit.

DESIRED FUTURE CONDITION: A portrayal of the land or resource conditions which are desired to 

result in the future with, or without active management.

DEVELOPED RECREATION: Recreation that occurs where improvements enhance recreation 

opportunities and accommodate intensive recreation activities in a defined area.

DEVELOPED RECREATION SITES: Relatively small, distinctly defined areas where facilities are 

provided for concentrated public use (i.e., campgrounds, picnic areas, and swimming areas).

DIRECT EFFECTS: Effects on the environment which occur at the same time and place as the initial 

cause or action.

DISPERSED RECREATION: Outdoor recreation in which visitors are diffused over relatively large 

areas. Where facilities or developments are provided, they are more for access and protection of the 

environment than for the comfort and convenience of the people.

DISPLACEMENT (Soil Displacement): The removal and horizontal movement of soil from one place to 

another, usually by mechanical forces such as dozer blades, repeated vehicular traffic, or the yarding of 

logs.

DISTURBANCE: Any event which affects the structure, function, composition, and/or successional 

development of a plant community (e.g., fire, insect attack, windthrow, timber harvest).

DIURNAL: Daily, especially pertaining to cyclic actions which are completed within 24 hours, and which 

recur every 24 hours, such as temperature, relative humidity and wind.

DIVERSITY: The relative distribution and variety of plant and animal communities and species within an 

area.

DOWN WOODY MATERIAL: A component of forest habitats used by wildlife for feeding, denning, 

and shelter. 

DUFF: The partially decomposed organic material of the forest floor beneath the litter or freshly fallen 

twigs, needles and leaves. See litter. 

ECOBURN: A prescribed fire for which at least one objective is to restore or enhance the condition of an 

area by approximating the results of a fire burning under conditions of the natural fire regime. 
Appendix D - Glossary

Lower West Fork Project Final EIS D-5

ECOSYSTEM: A complete, interacting system of living organisms and the land and water that make up 

their environment; the home places of all living things, including humans.

ECOSYSTEM MANAGEMENT: Scientifically based land and resource management that integrated 

ecological capabilities with social values and economic relationships, to produce, restore, or sustain 

ecosystem integrity, values, and services over the long term. 

EFFECTIVE GROUND COVER: Effective ground cover consists of vegetation, fine organic matter, 

coarse woody material, and rock fragments larger than three-fourths inch in diameter in contact with the 

soil surface.

EFFECTIVE WIND SPEED: The mid-flame wind speed adjusted for the upslope effect on fire spread. 

EFFECTS: Environmental consequences (the scientific and analytical basis for comparison of alternatives) 

as a result of a proposed action. Effects may be either direct, which are caused by the action and occur at 

the same time and place, or indirect, which are caused by the action and are later in time or farther removed 

in distance, but are still reasonably foreseeable, or cumulative.

ELK HABITAT EFFECTIVENESS (EHE): An index of the capability of an area to provide protection 

for elk. It is based on the density of roads open to public motorized use per square mile. 

ELK SECURITY AREA: A contiguous block of cover over 250 acres in size and at least 1/2 mile from an 

open road.

ENDANGERED SPECIES: Any plant or animal species which is in danger of extinction throughout all or 

a significant portion of its range (Endangered Species Act of 1973). 

ENDEMIC: Native or characteristic of a particular geographic area.

ENVIRONMENTAL ANALYSIS: An analysis of proposals and their predictable environmental effects, 

including physical, biological, economic, and social consequences and their interactions; short and longterm effects; and direct, indirect, and cumulative effects.

ENVIRONMENTAL ASSESSMENT (EA): A concise public document which serves to: (a) briefly 

provide sufficient evidence and analysis for determining whether to prepare an environmental impact

statement or a Finding of No Significant Impact; (b) aid in agency's compliance with the National 

Environmental Policy Act when no environmental impact statement is necessary; and (c) facilitate 

preparation of an environmental impact statement when necessary.

ENVIRONMENTAL IMPACT STATEMENT (EIS): A detailed statement prepared by the responsible 

official in which a major federal action which significantly affects the quality of the human environment is 

described, alternatives to the proposed action provided, and effects analyzed.

EPHEMERAL STREAMS: Streams that flow only as a direct response to rainfall or snowmelt events. 

They have no baseflow.

EPIDEMIC: The populations of plants, animals, and diseases that buildup, often rapidly, to highly 

abnormal and generally injurious levels and affect a large number of the host population throughout an area 

at the same time.

EROSION: Detachment or movement of soil or rock fragments by water, wind, ice, or gravity. 

Accelerated erosion is much more rapid than normal, natural, or geologic erosion, primarily as a result of 

the influence of activities of people, animals, or natural catastrophes. 

EXTREME FIRE BEHAVIOR: Implies a level of wildfire behavior characteristics that ordinarily 

precludes methods of direct attack. One or more of the following is usually involved: High rates of spread; 

prolific spotting and or crowning; presence of fire whirls; a strong convection column. Predictability is 

difficult because such fires often exercise some degree of influence on their environment, behaving 

erratically and sometimes dangerously. 

FILL SLOPE: Road construction slopes that are made by depositing soil from excavated areas.

FINE FUELS: Fuels such as grass, needles, fern, tree moss, some slash types & leaves which ignite 

readily and are consumed rapidly when dry. Also called flash fuels. 
Appendix D - Glossary

D- 6 Lower West Fork Project Final EIS 

FINE ORGANIC MATTER: Organic materials such as plant litter, duff, and woody material less than 3 

inches in diameter in contact with the soil.

FIRE BEHAVIOR: The manner in which a fire reacts to the influences of fuel, weather, and topography.

FIRE INTENSITY: The rate of heat release for an entire fire at a specific point in time. 

FIREBRAND: Any source of heat, natural or manmade, capable of igniting wildland fuels. Flaming or 

glowing fuel particles that can be carried naturally by wind, convection currents, or by gravity into 

unburned fuels. 

FIRE CYCLE: (Also called Fire Return Interval) The average time between fires in a given area.

FIRE-DEPENDENT: Forests, grasslands, and other ecosystems historically composed of species that 

evolved with and are maintained by periodic fire.

FIRE GROUP: Coniferous vegetation with a similar fire response, fire behavior, and plant response. 

FIRE HAZARD: The rapid ignition of fuels dependent on arrangement, volume, and conditions to sustain 

fire.

FIRE INTENSITY: The rate of heat release for an entire fire at a specific point in time. See fireline 

intensity.

FIRE LINE: The part of a control line that is scraped or dug to mineral soil. Sometimes referred to as a 

fire trail. See control line.

FIRELINE INTENSITY: The rate of heat energy released during combustion per unit length of fire front. 

It is usually expressed in BTUs/second/foot.

FIRE MANAGEMENT PLAN: A strategic plan that defines a program to manage wildland and prescribed 

fires and documents the Fire Management Program in the approved land use plan. The plan is 

supplemented by operational procedures such as preparedness plans, preplanned dispatch plans, prescribed 

fire plans and prevention plans. (NWCG terminology adopted 06/12/97) 

FIRE REGIME: The characteristics of fire in a given ecosystem, such as the frequency, predictability, 

intensity, seasonality, and extent in an ecosystem. Examples include: nonlethal, lethal (stand-replacing), 

and mixed lethal.

FIRE REGIME CONDITION CLASS: Departure from natural vegetation and disturbance regimes. 

FIRE RISK: The chance that a fire will ignite as affected by the nature and incidence of causative agents 

(also see Fire Hazard).

FIRE SEASON: The period or periods of the year during which wildland fires are likely to occur, spread 

and do sufficient damage to warrant organized fire suppression activities. 

FIRE SEVERITY: Soil impacts (BAER Handbook, FSH 2509.13):

High Severity – More than 40% of the polygon exhibits soil features likely to significantly increase 

runoff and erosion (e.g., absence of duff layer, hydrophobic soils, and soil discoloration). High 

severity fires are lethal to conifers with all needles burned off of the trees. 

Moderate Severity – Less than 40% of the polygon exhibits high severity indicators. Duff layers 

may be absent or mostly absent. Moderate severity fire kill the majority of conifers and needles on 

trees are scorched (brown). 

Low Severity – Duff layers are burned but intact. Unburned areas are intermingled with lightly 

burned areas. Low severity fires cause some tree mortality (torching) but stands have a notable live 

tree component.

Low Severity – green islands with spotty underburn. May find fire damage on only small dense 

pockets of regeneration within understory. Overstory basically has minor to no bole char and 

minor to no crown scorch.

FIRE SEVERITY: Vegetation impacts: For this project, the following vegetation severity definitions 

were used: 
Appendix D - Glossary

Lower West Fork Project Final EIS D-7

High Severity – total bole charring and no needles remain on trees

Medium Severity – heavy bole char, greater than 10 feet in height and on all sides of the tree. 

Crown scorch damage (or radiant heat damage) of 70% or greater of the crown with a minimum of 

30% live crown remaining. Medium severity effects can be found as a thin strip between the high 

severity areas and moderately low to low severity areas as well as in larger size pockets. 

Moderately Low – light underburn throughout with some crown scorching (scorch on less than 10 

to 30% of the crown), small amount of bole char less than 4 feet in height and char could be around 

entire tree or only partially circle the tree bole. 

Low Severity – green islands with spotty underburn. May find fire damage on only small dense 

pockets of regeneration within understory. Overstory basically has minor to no bole char and 

minor to no crown scorch.

FIRE-TOLERANT: A plant which has properties or characteristics which enable it to survive fire. 

FIRE USE: The combination of wildland fire use and prescribed application of fire to meet resource 

objectives.

FISH HABITAT: The place where a population of fish species lives and its surroundings; provides life 

requirements such as food and cover.

FISHERY: The total population of fish in a stream or body of water and the physical, chemical, and 

biological factors affecting that population. 

FLAME LENGTH: The distance measured from the tip of the flame to the middle of the flaming zone at 

the base of the fire. It is measured on a slant when the flames are tilted due to the effects of wind and/or 

slope. 

FLOODPLAIN: The lowland and relatively flat areas adjoining inland and coastal waters, including, at a 

minimum, that area subject to a one percent or greater chance of flooding in any given year.

FOREST COVER TYPE: A descriptive classification of actual or potential forest or forest land defined 

by its vegetative composition and/or locality factors. 

FOREST PLAN: Refers to the various Forest Plans for each national forest, or specifically to the 

Bitterroot National Forest Plan. 

FOREST HEALTH: The condition in which forest ecosystems sustain their complexity, diversity, 

resiliency, and productivity while providing for human needs and values. It is a useful way to 

communicate about the current condition of the forest, especially with regard to resiliency, a part of forest 

health that describes the ability of the ecosystem to respond to disturbances. Forest health and resiliency 

can be described, in part, by species composition, density, and structure. 

FRAGMENTATION: The process of removing links between areas of habitat suitable for a species, or 

the reduction of contiguous blocks of vegetation with similar structure and form into smaller isolated parts.

FUEL BED: An array of fuels usually constructed with specific loading, depth, and particle size to meet 

experimental requirements; also, commonly used to describe the fuel composition in natural settings.

FUEL LOAD: The amount of fuel present expressed quantitatively in terms of weight of fuel per unit area, 

usually expressed in tons per acre.

FUEL MOISTURE (FMC): The quantity of moisture in fuel expressed as a percentage of the weight when 

thoroughly dried at 212F. 

FUEL REDUCTION: Manipulation, including combustion, or removal of fuels to reduce the likelihood of 

ignition and/or to lessen potential damage and resistance to control.

FUEL TYPE: An identifiable association of fuel elements of a distinctive plant species, form, size, 

arrangement, or other characteristics that will cause a predictable rate of fire spread or difficulty of control 

under specified weather conditions. Also referred to as fuel model.
Appendix D - Glossary

D- 8 Lower West Fork Project Final EIS 

FUELS MANAGEMENT: Manipulation or reduction of fuels to meet Forest protection and management 

objectives while preserving and enhancing environmental quality.

FUELS TREATMENT: The rearrangement or disposal of fuels to reduce the fire hazard.

GROUND FIRE: Fire that consumes the organic material beneath the surface litter.

GROUND FUELS: All combustible fuels lying beneath the ground surface including deep duff, roots, 

rotten buried logs, peat and other woody debris. 

HABITAT: A place that provides seasonal or year round food, water, shelter, and other environmental 

conditions for an organism, community, or populations of plants or animals.

HABITAT COMPONENT: A simple part or a relatively complex entity regarded as a part, or an area or 

type of environment in which an organism or biological population normally lives or occurs.

HABITAT DIVERSITY: The variation in types, sizes, and shapes of landscape elements or vegetation 

types.

HABITAT EFFECTIVENESS: The ability of an area to support a species (individual or population) 

based on a potential of 100%.

HABITAT TYPE: The land area capable of supporting a single plant association. Provides a way to 

classify land area.

HABITAT TYPE GROUP: A grouping of habitat types based on similarities in natural disturbance 

regimes, successional patterns and structural characteristics of mature stands. 

HANDPILE and BURN: Fuels treatment method used to reduce hazardous fuels concentrations. Material 

is piled by hand. Piles are burned under conditions when the risk of fire spread is minimal. 

HAZARD: A fuel complex defined by kind, arrangement, volume, condition, and location that form a 

special threat of ignition or suppression difficulty. 

HAZARD QUOTIENT: An estimate of herbicide exposure based on the ratio of the amount of received 

from a particular exposure scenario to the estimated dose.

HIDING COVER: Vegetation capable of hiding 90% of a standing adult deer or elk at 200 feet or less. 

Includes some shrub stands and all forested stand conditions with adequate tree stem density or shrub layer 

to hide animals. In some cases, topographic features also can provide hiding cover.

HYDROLOGIC FUNCTION: Soil hydrologic function is the ability of the soil to absorb, store, and 

transmit water, both vertically and horizontally. Changes in soil bulk density, soil structure, and ground 

cover can alter the hydrologic function of the soil.

HYDROLOGIC UNIT CODE (HUC): The United States is divided and sub-divided into successively 

smaller hydrologic units which are classified into four levels: regions, sub-regions, accounting units, and 

cataloging units. The hydrologic units are arranged within each other, from the smallest (cataloging units) 

to the largest (regions). Each hydrologic unit is identified by a unique hydrologic unit code (HUC) 

consisting of two to eight digits based on the four levels of classification in the hydrologic unit system.

IMPROVEMENT CUT: Removing trees of undesirable species, form, or condition from the main canopy 

in stands past the sapling stage to improve the composition and quality of the remaining stand.

INDIRECT EFFECTS: Secondary effects which occur in locations other than where the initial action 

occurs or significantly later in time.

INFISH (Inland Native Fish Strategy): On July 31, 1995, the Decision Notice for Inland Native Fish 

Strategy Environmental Assessment (INFISH) was signed. This strategy was developed to provide interim 

direction to protect habitat and populations of native resident fish until longer-term conservation strategies 

such as the Upper Columbia River Basin and federal recovery plans replaced it .

INITIAL ATTACK: An aggressive suppression action consistent with firefighter and public safety and 

values to be protected. 
Appendix D - Glossary

Lower West Fork Project Final EIS D-9

INTERDISCIPLINARY TEAM (ID Team): A group of resource professionals with different expertise 

that collaborate to develop and evaluate resource management proposals. The team is assembled out of 

recognition that no one scientific discipline is sufficiently broad to adequately address resource 

management activities.

INTERMEDIATE TREATMENT: Any treatment or tending designed to enhance growth, quality, vigor, 

and composition of the stand after establishment or regeneration and prior to final harvest. Thinning, 

salvage, and improvement cuts are all types of intermediate treatments.

INTERMITTENT STREAM: A stream which flows only at certain times of the year when it receives 

water from springs or from some surface source such as melting snow. An intermittent stream shows clear 

evidence of annual scour. Gullies that washed out during flood events are not considered intermittent 

streams.

INVENTORIED ROADLESS AREA: Undeveloped areas typically exceeding 5,000 acres that met the 

minimum criteria for wilderness consideration under the Wilderness Act and that were inventoried during 

the Forest Service’s Roadless Area Review and Evaluation (RAREII) process, subsequent assessments, or 

Forest planning.

IRREVERSIBLE: A term that describes the loss of future options. Applies primarily to the effects of use 

of nonrenewable resources, such as minerals or cultural resources, or to those factors, such as soil 

productivity that are renewable only over long periods of time.

IRRETRIEVABLE: A term that applies to the loss of production, harvest, or use of natural resources. For 

example, some or all of the timber production from an area is lost irretrievably while an area is serving as a 

winter sports site. The lost production is irretrievable, but the action is not irreversible. If the use changes, 

it is possible to resume timber production.

ISSUE INDICATORS: Units of measure developed to facilitate comparison of major issues.

JACKPOT BURNING: A fuel reduction/site preparation treatment in which a continuous fuel bed is not 

present. Jackpot burning is conducted when fuels tend to be scattered with isolated accumulations 

distributed across the treatment unit. 

LADDER FUELS: Fuels that can carry a fire from the surface layer into the aerial fuel layer. This may 

include dense seedling/sapling size trees, dense tall brush and shrubs, heavy concentrations of coarse wood 

debris. 

LANDSLIDE PRONE AREAS: Areas which have a tendency toward instability (e.g., very steep slopes 

on erosive soils, old landslides, and areas with springs).

LANDTYPE: A unit of land with similar designated soil, vegetation, geology, topography, climate, and 

drainage. The basis for mapping units in the land systems inventory.

LARGE WOODY DEBRIS (LWD): Branches and/or tree trunks located within a stream channel, 

originating from trees growing in or near the channel. Such material is considered “large” if it is of 

sufficient size that it remains at least partially submerged during all but major flood events. These 

materials are important in stream systems because they serve a variety of functions related to channel 

hydraulics and morphology. In mountain streams, LWD is very important because it provides excellent 

hiding cover and forms pools, which are the best fish habitats. Functions would include flow energy 

reduction due to friction and turbulence on downstream side of debris, and sediment storage on upstream 

side of materials. LWD is delivered to stream channels by decay and/or windfall of trees in close 

proximity.

LETHAL FIRES: A descriptor of fire response and effect in forested ecosystems of high-severity or 

severe fire that burns through the overstory and understory which consumes large woody surface fuels and 

may consume entire duff layer. 

LITTER: The uppermost layer of loose debris composed of freshly fallen or slightly decomposed organic 

materials such as dead sticks, branches, twigs, and leaves or needles. 
Appendix D - Glossary

D- 10 Lower West Fork Project Final EIS 

MANAGEMENT AREA: Geographic areas, not necessarily contiguous, which have common 

management direction, consistent with the Forest Plan allocations.

MANAGEMENT INDICATOR SPECIES (MIS): A fish or wildlife species selected for monitoring 

because their population changes are believed to indicate the effects of management activities on other 

species of selected major biological communities or on water quality. 

MANAGEMENT IGNITED FIRE: See Prescribed Burning. (Obsolete terminology) 

MASS EROSION (MASS WASTING): Downslope movement of a unit of soil. Mass erosion includes 

landslides, debris flows, debris avalanches, debris torrents, slumps, and soil creeping.

MATURE: In forested vegetation, individual trees or stands of trees that in general are at their maximum 

rate in terms of physiological processes expressed as height, diameter, and volume growth. In the context 

of wildlife, refers to mature forest habitat with characteristics needed to provide habitat for species such as 

pine marten and pileated woodpecker (generally occurs around age 100). 

MITIGATION: Actions to avoid, minimize, reduce, eliminate, replace, or rectify the impact of a 

management practice.

MIXED SEVERITY: Units that have a combination of high, moderate, and low degrees of severity and 

may depend on fuel loading and placement. 

MONITORING AND EVALUATION: The evaluation of Forest Plan management practices to determine 

how well objectives are being met, as well as the effects of those management practices on the land and 

environment.

MOTOR VEHICLE: Any vehicle which is self-propelled, other than:

(1) a vehicle operated on rails; and

(2) any wheelchair or mobility device, including one that is battery-powered, that is designed solely 

for use by a mobility-impaired person for locomotion, and that is suitable for use in an indoor 

pedestrian area.

NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS): A legal limit on the level of 

atmospheric contamination. The level is established as the concentration limits needed to protect all of the 

public against adverse effects on public health and welfare, with an adequate safety margin. Primary 

standards are those related to health effects. Secondary standards are designed to protect the public welfare 

from effects such as visibility reduction, soiling, material damage, and nuisances.

NATIONAL ENVIRONMENTAL POLICY ACT: A United States environmental law that established a 

U.S. national policy promoting the enhancement of the environment and also established the President’s 

Council on Environmental Quality (CEQ). 

NATIONAL FOREST MANAGEMENT ACT (NFMA): A law passed in 1976 as amendments to the 

Forest and Rangeland Renewable Resources Planning Act that requires the preparation of Regional and 

Forest Plans and the preparation of regulations to guide that development.

NATIVE SPECIES: Those plant and animal species indigenous to the planning or assessment area.

NEW ROAD CONSTRUCTION: Activity that results in the addition of Forest classified or temporary 

road miles. 

NONCOMMERCIAL THINNING: A thinning done purely as an investment in the future growth of a 

stand. Tree thinned are small in size and usually have no value. Material thinned may be left in place, 

piled and piles burned, or extracted based on management objectives Noncommercial thinning could also 

include release thinnings, weeding thinnings, improvement cuttings and pruning. 

NON-LETHAL FIRES: A descriptor of fire response and effect in forested ecosystems of low severity or 

cool fire. Has minimal impact on the site. It burns in surface fuels consuming only the litter, herbaceous 

fuels, foliage, and small twigs on woody undergrowth. Little heat travels downward through the duff. 
Appendix D - Glossary

Lower West Fork Project Final EIS D-11

NONSTOCKED: A stand of trees or aggregation of stands that have a stocking level below the minimum 

specified for meeting the prescribed management objectives.

NOXIOUS WEEDS: Rapidly spreading plants which can cause a variety of major ecological impacts to 

both agricultural and wild lands. A plant species designated as possessing one or more of the following 

characteristics: aggressive and difficult to manage; parasitic; a carrier or host of serious insects or disease; 

or nonnative, new, or not common to the United States. According to the Federal Noxious Weed Act (PL 

93-639) a noxious weed is one that causes disease or has other adverse effects on people or their 

environment and therefore is detrimental to the agriculture and commerce of the United States and to the 

public health.

OFF-HIGHWAY VEHICLE: Any motorized wheeled vehicle designed for cross-country travel over any 

type of terrain.

FOREST SERVICE OFF-ROAD VEHICLE DESIGNATIONS:

Open: Areas and trails on which all types of motorized vehicles may be operated off roads without 

restrictions.

Restricted: Areas and trails on which motorized vehicle use is restricted by times or specified in 

orders issued under the authority of 36 CFR 261 or by law.

Closed: Areas and trails on which all motorized vehicle use is prohibited, except by permit, under 

authority of 36 CFR 361 or by law. 

OLD-GROWTH HABITAT: Old-growth is a distinct successional stage in the development of a forest

stand that has special significance for wildlife, generally characterized by: 

large diameter trees (often exceeding 19” dbh) with a relatively dense, often multilayered canopy; 

the presence of large, standing dead or dying trees; 

down and dead trees; 

stand decadence associated with the presence of various fungi and heartrots; 

an average age often in excess of 200 years.

OPEN ROAD DENSITY: A measure of the amount of open roads per area of land, usually expressed as 

miles per square mile.

OVERSTOCKED: Stands that exceed a prescribed standard based on the capability of the site and/or 

other values.

OVERSTORY: The portion of trees in a forest which forms the uppermost layer of foliage.

PARTICULATE MATTER (PM): Any liquid or solid particles. “Total suspended particulates” as used 

in air quality are those particles suspended in or falling through the atmosphere. They generally range in 

size from 0.1 to 100 microns.

PATCH: An area of vegetation that is relatively homogeneous internally with respect to composition and 

successional stage and that differs from what surrounds it.

PEAK FLOW: The greatest flow attained during the melting of the winter snowpack.

PERENNIAL STREAMS: Streams that flow continuously throughout the year.

POLES: A size category for forested vegetation in which trees are usually between 5 inches in diameter up 

to 9 inches in diameter. 

PRESCRIBED BURNING OR PRESCRIBED FIRE: Controlled application of fire to wildland fuels in 

either their natural or modified state, under specified environmental conditions which allow the fire to be 

confined to a predetermined area and at the same time to produce the intensity of heat and spread required 

to attain planned and approved resource management objectives. Also called controlled burning or 

formerly referred to as management ignited prescribed fire. A written, approved prescribed fire plan must 

exist and, requirements of the National Environmental Policy Act must be met, prior to ignition. (NWCG 

terminology adopted 06/12/97) 
Appendix D - Glossary

D- 12 Lower West Fork Project Final EIS 

PRESCRIBED NATURAL FIRE (PNF): A naturally occurring fire which is managed under prescribed 

conditions and allowed to "run its' course" without endangering public safety or significant resource losses. 

(Obsolete terminology) 

PRESCRIPTION - Fire: Measurable criteria that guide selection of appropriate management response and 

actions. Prescription criteria may include safety, economic, public health, environmental, geographic, 

administrative, social or legal considerations. (NWCG terminology adopted 06/12/97) 

PRESCRIPTION - Vegetation: See Silviculture Prescription definition.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD): A program identified by the Clean Air 

Act to prevent air quality and visibility degradation and to remedy existing visibility problems. Areas of 

the country are grouped into three classes which are allowed certain degrees of pollution depending on their 

uses. National Parks and Wilderness areas meeting certain criteria are “Class I” or “clean areas” in that 

they have the smallest allowable increment of degradation.

PROJECT AREA: The geographic area of activities proposed in the alternatives.

PROJECT FILE: An assemblage of documents that contains all the information developed or used during 

an environmental analysis. The Project File becomes part of the administrative record for judicial review in 

case of legal action.

PROPOSED ACTION: In terms of the National Environmental Policy Act, the project, activity, or action 

that a federal agency intends to implement or undertake and which is the subject of an environmental 

analysis.

PUBLIC PARTICIPATION: A Forest Service process designed to broaden the information base upon 

which agency decisions are made by: (1) informing the public about Forest Service activities, plans, and 

decisions; and (2) encouraging public understanding and participation in the planning processes which lead 

to final decision-making.

PUBLIC ISSUE (PUBLIC CONCERN): A subject or question of widespread public interest relating to 

management of the National Forest System.

RATE OF SPREAD (ROS): The relative activity of a fire in extending its horizontal dimensions over time. 

Expressed as a rate of increase of the total perimeter of the fire, as a rate of forward spread of the fire front, 

or as a rate of increase in area, depending upon the intended use of the information. Usually it represents 

the forward spread and is expressed in chains per hour or meters per hour for a specific period in the fire's 

history. 

REACH: A segment of a stream that contains similar physical characteristics (e.g., gradient, width, stream 

bottom materials). In general, most reaches are between 1 mile and 3 miles in length.

RECORD OF DECISION: A concise public document disclosing the decision made following 

preparation of an EIS and the rationale used by the Deciding Officer to reach that decision.

RECREATION OPPORTUNITY SPECTRUM (ROS): A range of possible combinations of recreation 

activities, settings, and experience opportunities, from Primitive to Urban, arranged along a continuum. 

Classes of recreation on the spectrum are:

Primitive (PRIM) - Area is characterized by essentially unmodified natural environment of fairly 

large size. Interaction between users is very low and evidence of other area users is minimal. The 

area is managed to be essentially free from evidence of man-induced restrictions and controls. 

Motorized use within the area is not permitted.

Non-Motorized (SPNM) - Area is characterized by a predominantly natural or natural-appearing 

environment of moderate-to-large size. Interaction between users is low, but there is often 

evidence of other users. The area is managed in such a way that minimum on-site controls and 

restrictions may be present, but are subtle. Motorized use is not permitted.

Semi-Primitive motorized (SPM) - Area is characterized by a predominantly natural or naturalappearing environment of moderate-to-large size. Concentration of users is low, but there is often 
Appendix D - Glossary

Lower West Fork Project Final EIS D-13

evidence of other area users. The area is managed in such a way that minimum on-site controls and 

restrictions may be present, but are subtle. Motorized use is permitted. 

Roaded Natural Appearing (RNA) - Area is characterized by predominantly natural-appearing 

environment with moderate evidences of the sights and sounds of man. Such evidences usually 

harmonize with the natural environment. Interaction between users may be low to moderate, but 

with evidence of other users prevalent. Resource modification and utilization practices are evident, 

but harmonize with the natural environment. Conventional motorized use is provided for in the 

construction standards and design facilities.

Rural (R) - Area is characterized by substantially modified natural environment. Resource 

modification and utilization practices are primarily to enhance specific recreation activities and to 

retain vegetative cover and soil. Sights and sounds of man are readily evident, and the interaction 

between users is often moderate to high. A considerable number of facilities are designed for use 

by a large number of people. Facilities are often provided for special activities. Moderate densities 

are provided far away from developed sites. Facilities for intensified motorized use and parking 

are available.

Urban (U) - Area is characterized by substantially urbanized environment though the background 

may have a natural appearance. Resource modification and utilization practices enhance specific 

recreation activities. Vegetation cover is often exotic and manicured. Sights and sounds of 

humans are predominant. Large numbers of users can be expected both on-site and in nearby 

areas. Facilities for highly intensified motor use and parking are available with forms of mass 

transit often available to carry people throughout the site.

REFERENCE DOSAGE: A very conservative toxicological threshold of chronic herbicide exposure that 

assumes daily exposure over a 70-year lifespan.

REGENERATION: The renewal of a tree crop, whether by planting or natural means. This term may also 

refer to the crop (i.e., seedlings, saplings) itself.

REGENERATION HARVEST: Used in reference to even aged treatment such as clearcut, seedtree, and 

shelterwood harvest methods which remove an existing stand to prepare a site for regeneration. 

REHABILITATION (Soil): - Treatments that restore vital soil functions to their inherent range of 

variability. It is recognized that treatments may need to occur over a period of years and may need to be 

maintained. Restoration treatments could include but are not limited to, tillage, ripping, seeding, mulching, 

recontouring, and water barring.

RELEASE THINNING: Freeing a tree from immediate competition by cutting or otherwise eliminating 

growth that is overtopping or closely surrounding the tree. May be done for incidental disease control 

work, release of natural and planted regeneration, and accompanying work to eliminate related fuel 

accumulations.

RESERVE TREE: Trees retained after the regeneration period (pole-sized or larger) under the 

clearcutting, seed tree, or shelterwood methods.

RESIDUAL TREE: Trees remaining after an activity or disturbance event.

RESPONSIBLE OFFICIAL: The Forest Service line officer who has the authority and responsibility to 

oversee the planning process and make decisions on proposed actions. May also be referred to the 

Deciding Official.

RESTORATION (Forest): Holistic approach taken to modify an ecosystem to achieve desired, healthy, 

and functioning conditions and processes. Deliberate alteration of ecological patterns and processes to

recreate presumed sets of natural, pre-disturbance ecosystem conditions. Restored forests are therefore 

similar in structure, function and composition to historic forests. Generally refers to the process of 

enabling the system to resume it resiliency to disturbance. 

RESTORE: Management emphasis designed to move ecosystems to desired conditions and processes, 

and/or to healthy forestlands, rangelands, and aquatic systems; a variety of management-induced activities 
Appendix D - Glossary

D- 14 Lower West Fork Project Final EIS 

dominate the landscape. Generally, “restore” strategies are applied to areas of moderate to low ecological 

integrity.

RILL/GULLY: A channel or miniature valley cut by concentrated runoff, through which water commonly 

flows only during and immediately after heavy rains or during the melting of snow. 

RIPARIAN AREAS/HABITATS: Land where the vegetation and microclimate are influenced by 

perennial and/or intermittent water.

RIPARIAN HABITAT CONSERVATION AREA (RHCA): As established by the Inland Native Fish 

Strategy, RHCAs are portions of watersheds where riparian-dependent resources receive primary emphasis 

and management activities are subject to specific standards and guidelines. Examples of RHCAs include 

traditional riparian corridors, wetlands, intermittent streams, and other areas that help maintain the integrity 

of aquatic ecosystems.

RIPARIAN MANAGEMENT OBJECTIVE (RMO): Objectives specified by the Inland Native Fish 

Strategy regarding how Riparian Habitat Conservation Areas are to be managed. These objectives apply to 

factors such as pool frequency, large woody debris, mean-maximum temperature, and mean wetted widthdepth ratios.

ROAD: A motor vehicle travelway over 50 inches wide, unless designated and managed as a trail. A road 

may be classified, unclassified, or temporary.

Classified Road: Roads wholly or partially within or adjacent to National Forest System lands that 

are determined to be needed for long-term motor vehicle access, including State roads, county 

roads, privately owned roads, National Forest System roads, and other roads authorized by the 

Forest Service. 

Arterial Road: A Forest road that provides service to a large land area and usually connects with 

other arterial roads or public highways.

Collector Road: A Forest road that serves smaller land areas than an arterial road, and usually 

connects Forest arterial roads to local Forest roads or terminal facilities.

Local Road: A Forest road that connects terminal facilities with Forest collector, Forest arterial, or 

public highways. Usually Forest local roads are single purpose transportation facilities.

Temporary Road: Roads authorized by contract, permit, lease, other written authorization, or 

emergency operation not intended to be part of the forest transportation system and not necessary 

for long-term resource management.

Unclassified Road: Roads on National Forest System lands that are not managed as part of the 

Forest transportation system, such as unplanned roads, abandoned travelways, and off-road vehicle 

tracks that have not been designated and managed as a trail; and those roads that were once under 

permit or other authorization and were not decommissioned upon the termination of the 

authorization.

ROAD DENSITY: Number of miles of open road per square mile.

ROAD MAINTENANCE: The ongoing upkeep of a road necessary to retain or restore the road to the 

approved road management objective.

ROADED NATURAL RECREATION SETTING: A classification on the recreation opportunity 

spectrum where timber harvest or other surface use practices are: - evident. Motorized vehicles are 

permitted on all or parts of the road system.

ROSGEN STREAM TYPE CLASSIFICATION: A system of measure that utilizes various channel 

features to rate a stream or river into reproducible classes.

ROTATION: The planned number of years required to establish (including a regeneration period) and 

grow timber crops to a specified condition 

RUTTING: Deformation of the soil under saturated conditions resulting in detrimental changes to soil 

structure and reduced porosity.
Appendix D - Glossary

Lower West Fork Project Final EIS D-15

SALMONIDS: Members of the family of elongate soft-finned fishes Salmonidae - the trout and salmon 

family.

SALVAGE: Removal of trees that are dead, dying, deteriorating, or in danger of being killed by injurious 

agents. A manageable stand still remains after a salvage treatment.

SANITATION: The removal of dead, damaged, or insect and disease susceptible trees to prevent the 

spread of pests or pathogens.

SAWLOG: A log that meets minimum regional standards of diameter, length, and defect, intended for 

sawing.

SAWTIMBER: Trees containing at least one 8-foot piece with a 5.6 inch diameter inside bark at the small 

end and meeting Regional specification for defect percentage. Trees must be at least 6.9 inches in diameter 

at breast height for all species except lodgepole pine which will be 6 inches at breast height. 

SCOPING: The procedures by which the Forest Service collects input in the environmental analysis 

process. This information is used to determine: the extent of analysis necessary; the range of actions, 

alternatives, and impacts to be addressed; the significant issues related to the proposed action; and the depth 

of environmental analysis, data, and task assignments needed.

SEDIMENT: Any material carried in suspension by water, which will ultimately settle to the bottom. 

Sediment has two main sources: from the stream channel area itself and from disturbed sites.

SEDIMENT (DEPOSITION) – See Aggregation (Deposition)

SEDIMENT TRAP: Any natural or man-made feature in a stream that traps sediment.

SEED TREE METHOD: Removal of the mature timber in one cutting, except for a small number of seed 

trees left singly or in small groups. 

SEEDLING AND SAPLINGS: A size category for forested stands in which trees are less than 5 inches in 

diameter. 

SENSITIVE SPECIES: Those species identified by the Regional Forester for which population viability 

is a concern as evidenced by significant current or predicted downward trends in (a) population numbers or 

density, or (b) habitat capability that would reduce a species' existing distribution.

SENSITIVITY LEVEL: A particular degree or measure of viewer interest in the scenic qualities of the 

landscape.

SUCCESSIONAL STAGE (Seral Stage): The series of plant community conditions that develop during 

ecological succession from bare ground (or major disturbance) to the climax stage. Early seral stage is a 

condition in which plants are present soon after a disturbance or at the beginning of a new successional 

process (seedling or saplings in a forest). Grass, herbs, or brush are abundant, diversity is high. A midseral stage is characterized in a forest setting has almost full crown closure in pole-to medium-sized trees. 

Understory vegetation and species diversity is less due to tree shading. A late seral stage is a condition 

with mature trees, often of old forest character. Tree growth has slowed, mortality has increased, 

understory forage is minimal, structural diversity may be high, and species diversity is generally less.

SHELTERWOOD METHOD: Removal of the mature timber in a series of cuttings, which extend over a 

relatively short portion of the rotation, by means of which the establishment of essentially even-aged 

reproduction under the partial shelter of seed trees is encouraged. 

SIGNIFICANT: As used in NEPA, requires consideration of both context and intensity. Context means 

that the significance of an action must be analyzed in several contexts such as society as a whole, and the 

affected region, interests, and locality. Intensity refers to the severity of impacts (40 CFR 1508.27).

SILVICULTURE: The art and science of manipulating forest vegetation to meet a desired future 

condition based on land management objectives.

SILVICULTURE DIAGNOSIS: The processes of comparing existing stand conditions to a desired 

condition or “target stand”, and determining a need for treatment to bring the stand to the desired condition, 

based on land management objectives.
Appendix D - Glossary

D- 16 Lower West Fork Project Final EIS 

SILVICULTURE PRESCRIPTION: A detailed written document that describes management activities 

needed to implement silvicultural treatment or treatment sequence. The prescription documents the results 

of an analysis of present and anticipated site conditions and management direction. It also describes the 

desired future vegetation conditions in measurable terms. The desired condition is a basis for treatment, 

monitoring, and evaluation. 

SILVICULTURAL SYSTEM: A management process whereby forests are tended, harvested, and 

replaced, resulting in a forest of distinctive form. The system name is based on the number of age classes 

(e.g., even-aged, two aged, uneven-aged) or the regeneration method (e.g., clearcutting, seed tree, 

shelterwood, selection) used. 

SLASH: Debris left on the ground after treatment activities and/or as a result of storm or fire damage. The 

term slash usually refers to small diameter seedlings, saplings, poles, logs, branches, stumps, and/or broken 

understory trees or brush.

SLASH DISPOSAL: Treatment of slash to reduce the fire hazard or for other purposes.

SLASHING: Slashing consists of felling and/or limbing small diameter vegetation to improve residual tree 

growth, vigor and healthy or to prepare an area for underburning where ladder fuels may be a problem. 

Slashing may be done in conjunction with other treatments including thinnings, piling, and burning. 

SMOKE MANAGEMENT PLAN: A forecast issued daily during specific periods advising fire managers 

of atmospheric conditions with special emphasis on elements which will affect the dispersal of pollutants 

from a fire. 

SNAG: A dead, standing tree.

SNAG-DEPENDENT WILDLIFE: Wildlife species that are dependent on standing dead trees for nesting 

or roosting habitat or for food.

SOIL FUNCTION: Primary soil functions are: (1) the sustenance of biological activity, diversity, and 

productivity, (2) soil hydrologic function, (3) filtering, buffering, immobilizing, and detoxifying organic 

materials, and (4) storing and cycling nutrients and other materials.

SOIL PRODUCTIVITY: The capacity of a soil to produce a specific crop such as fiber and forage, under 

defined levels of management. It is generally dependent on available soil moisture and nutrients and length 

of growing season.

SOIL QUALITY: The capacity of a specific soil function within its surroundings, support plant and 

animal productivity, maintain or enhance water and air quality, and support human health and habitation.

SPECIES: A unit of classification of plants and animals consisting of the largest and most inclusive array 

of sexually reproducing and cross-fertilizing individuals which share a common gene pool.

SPECIES VIABILITY: A species consisting of self-sustaining and interacting populations that are well 

distributed through the species' range. Self-sustaining populations are those that are sufficiently abundant 

and have sufficient genetic diversity to display the array of life history strategies and forms to provide high 

likelihood for their long-term persistence and adaptability over time.

STAND: A community of trees or other vegetation uniform in composition, constitution, spatial 

arrangement, or condition to be distinguishable from adjacent communities.

STAND COMPOSITION: The unique representation of tree species and structural characteristics of any 

forest stand.

STAND DENSITY: Refers to the number of trees growing in a given area. Can be expresses in terms of 

trees per acre, basal area per acre, stand density index and/or other measures. 

STAND-REPLACING FIRE: A fire that kills most or all of a stand of trees.

STAND STRUCTURE: The horizontal and vertical arrangement of the vegetation in a stand. The 

components of stand structure might include tree diameter, heights, crown layers, number of stems, shrubs, 

herbaceous understory, snags, and down logs.
Appendix D - Glossary

Lower West Fork Project Final EIS D-17

STANDARD: A particular action, level of performance, or threshold specified by the Forest Plan for 

resource protection or accomplishment of management objectives. Unlike “guidelines” which are optional, 

standards specified in the Forest Plan are mandatory.

STATE IMPLEMENTATION PLANS: A plan required by the Clean Air Act and prepared by an Air 

Quality Regulatory Agency, which describes how the state will attain and maintain air quality so as to not 

violate National Air Ambient Air Quality Standards.

STOCKING: A measure of tree density as it relates to an optimum or desired density to achieve a given 

management objective. 

STREAM: A natural watercourse of perceptible extent that has a generally sandy or rocky bottom or 

definite banks and that confines and conducts continuously or intermittently flowing water. "Perceptible 

extent" means that 50% of a 100-foot segment meets the definition of a stream (Montana Streamside 

Management Law). 

STREAM CHANNEL STABILITY: A classification system that utilizes ocular estimates of various 

channel, bank, and riparian area features to evaluate channel health.

STRUCTURAL DIVERSITY: The variation in sizes and shapes of landscape elements, as well as 

diversity of pattern (i.e., heterogeneity).

SUBPOPULATION: A geographically distinct segment of a larger population. For example, the bull 

trout in Mill Creek area subpopulation of the larger bull trout population in the entire Bitterroot River 

Drainage.

SUCCESSION: A predictable process of changes in structure and composition of plant and animal 

communities over time. Conditions of the prior plant community or successional stage create conditions 

that are favorable for the establishment of the next stage. The different stages in succession are often 

referred to as seral stages, refer to seral stage definition.

SUCCESSIONAL STAGE: A stage or recognizable condition in the gradual supplanting of one 

community of plants by another.

SUMMER RANGE: range, usually at higher elevation, used by deer and elk during the summer; a 

summer range is usually much more extensive than a winter range.

SUPPRESSED: Refers to individual trees which are growing very slowly. The trees have their crowns in 

the lower layers of the canopy and the leading shoots are not free. 

SUPPRESSION (FIRE SUPPRESSION): Any act taken to extinguish, slow, or stop a fire beginning with 

its discovery. Examples of suppression activities include fireline construction, backfiring, and applying 

water or chemical fire retardants.

SURFACE EROSION: The detachment and transport of individual soil particles by wind, water, or 

gravity. Surface erosion is the loss of soil in a fairly uniform layer across the land surface (sheet erosion), 

in many small rills, or as larger gullies.

SURFACE FIRE: Fire that burns surface litter, other loose debris and small vegetation.

SURFACE FUELS: All materials lying on, or immediately above, the ground, including needles or leaves, 

duff, grass, small dead wood, downed logs, stumps, large limbs, low brush and reproduction. 

TARGET STAND: A description of individual forest stands that reflects the desired future attributes and 

conditions that have the potential to meet management objectives.

THERMAL COVER: Vegetation used by animals to modify the adverse effects of weather. A forest 

stand that is a least 40 feet in height with tree canopy cover of at least 70 percent provides thermal cover. 

These stand conditions are achieved in closed sapling-pole stands and by all older stands unless the canopy 

cover is reduced below 70 percent. Deciduous stands may serve as thermal cover in summer, but not in 

winter.

THINNING: Intermediate cuttings that are aimed primarily at controlling growth of stands through 

adjustments in stand density. Thinning can be categorized as commercial or non-commercial.
Appendix D - Glossary

D- 18 Lower West Fork Project Final EIS 

THIN-FROM-BELOW: Removing trees from the lower crown classes to favor those in the upper crown 

classes.

THREATENED SPECIES: Any species of plant or animal which is likely to become endangered within 

the foreseeable future throughout all of a significant portion of its range.

TIMBER BASE: The lands within the Forest that are suitable for timber production.

TIMBER PRODUCTION: The purposeful growing, tending, harvesting, and regeneration of regulated 

crops of trees to be cut into logs, bolts, or other round sections for industrial or consumer use. 

TIMBER STAND IMPROVEMENT: A loose term comprising all intermediate cuttings made to 

improve the compositions and condition of the timber stand.

TIMBER TYPES: Refer to Forest Cover Type definition. 

TORCHING: Fire burning principally as a surface fire that intermittently ignites the crowns of trees or 

shrubs as it advances.

TRAIL: A commonly used term denoting a pathway for purposes of travel by foot, stock, or trail vehicles.

TURBIDITY: An optical measure of how fine sediment inhibits light transmission in a given water sample 

due to scattering and absorption by suspended particles.

UNDERBURN: A fuel reduction/site preparation treatment in which surface fuels are ignited under 

controlled conditions and are allowed to burn with specified parameters. Underburns are usually conducted 

in areas where the fuel bed is fairly continuous and conditions are such that fire will spread in a predictable 

and consistent fashion. Underburning implies that there is a live overstory present and often a live 

understory as well. Prescriptions for underburning usually include an acceptable mortality level in the live 

component.

UNDERSTORY: Vegetation (e.g., trees or shrubs) growing under the canopy formed by taller trees.

UNEVEN-AGED MANAGEMENT: The application of a combination of actions needed to 

simultaneously maintain continuous high-forest cover, recurring regeneration of desirable species, and the 

orderly growth and development of trees through a range of diameter or age classes to provide a sustained 

yield of forest products. Cutting is usually regulated by specifying the number or proportion of trees of 

particular sizes to retain within each area, thereby maintaining a planned distribution of size classes. 

Cutting methods that develop and maintain uneven-aged stands are single-tree selection and group 

selection.

UNIT: A treatment area that may undergo activity such as harvest, salvage, burning, or other purposes that 

is specified within boundaries.

UNMERCHANTABLE: Timber that does not meet minimum height and diameter specifications which 

would make it suitable for commercial sawtimber. 

UNROADED AREAS: Any area without the presence of a classified road (i.e., a road at least 50 inches 

wide and constructed or maintained for vehicle use) of a size and configuration sufficient to protect the 

inherent characteristics associated with its roadless condition. Unroaded areas do not overlap with 

inventoried roadless areas. 

VALUES AT RISK: Natural resources, improvements, or other values that may be jeopardized if a fire 

occurs.

VEGETATION RESPONSE UNITS (VRU): Refer to Habitat Type Group definition.

VERTICAL DIVERSITY: The diversity in an area that results from the complexity of the above ground 

structure of the vegetation; the more tiers of vegetation or the more diverse the species makeup is, the 

higher the degree of vertical diversity.

VIABLE POPULATION: A wildlife population of sufficient size to maintain its existence over time in 

spite of normal fluctuations in population levels.
Appendix D - Glossary

Lower West Fork Project Final EIS D-19

VISUAL QUALITY OBJECTIVE (VQO): A system of indicating the potential expectations of the 

visual resource by considering the frequency an area is viewed and the type of landscape. VQOs are listed 

below:

Maximum Modification: Human activities may dominate the characteristic landscape but should 

appear as a natural occurrence when viewed as background.

Modification: Human activity may dominate the characteristic landscape but must, at the same 

time, utilize naturally established form, line, color, and texture. It should appear as natural 

occurrence when viewed in foreground or middleground.

Partial Retention: Human activity may be evident but must remain subordinate to the 

characteristic landscape.

Retention: Human's activities are not evident to the casual Forest visitor.

Preservation: Provides for ecological change only.

Variety Class: Diversity of the landscape character.

Sensitivity Level

VISUAL RESOURCE: The composite of landforms, water features, vegetative patterns, and cultural 

features which create the visual environment. 

: A particular degree or measure of viewer interest in the scenic qualities of the 

landscape.

WATER YIELD: The measured output of the Forest's streams.

WEEDING THINNING: The elimination or suppressing undesirable vegetation, mainly herbaceous, 

during the seedling stage of a forest crop so as to reduce competition with the seedling stand. May also

include incidental disease control work, release of natural and planted regeneration, and accompanying 

work to eliminate related fuel accumulations.

WETLANDS: Those areas that are inundated by surface or ground water with a frequency sufficient, 

under normal circumstances, to support a prevalence of vegetative or aquatic life that requires saturated or 

seasonally saturated soil conditions for growth and reproduction. Wetlands include marshes, bogs, sloughs, 

potholes, river overflows, mud flats, wet meadows, seeps, and springs.

WHOLE TREE YARDING: During timber harvesting, entire trees are yarded to the landing. Tops, 

limbs, and other unmerchantable material is piled for later treatment and/or utilization at the landing site.

WILDERNESS: All lands included in the National Wilderness Preservation System by public law; 

generally defined as undeveloped Federal land retaining its primeval character and influence without 

permanent improvements or human habitation.

WILDLAND-URBAN INTERFACE (WUI): Includes those areas of resident human populations at 

imminent risk from wildland fire, and human developments having special significance. These areas 

include developments and structures that if destroyed by fire, would result in hardships to individuals and 

communities. These areas encompass not only the sites themselves but also the continuous slopes and fuels 

that lead directly to the sites, regardless of the distance involved.

WINTER RANGE: A range, usually at lower elevation, used by migratory deer and elk during the winter 

months. It is usually better defined and smaller than summer range.

WOODY DEBRIS RECRUITMENT: The process of trees naturally falling over and landing in stream 

channels.

YEAR-ROUND CLOSURE: Gate, earthen barrier, or sign closing a road or area all year long. These 

areas are sometimes open during harvest or other land management activities.

YARDING: A method of bringing material to a roadside or landing, for transport. Methods include forms 

of skyline cabling, ground-based skidding, balloon, and helicopter.
Appendix D - Glossary

D- 20 Lower West Fork Project Final EIS 

ABBREVIATIONS AND ACRONYMS

AIRFA 

ALT

APE

ARM

ARPA

ATV

BA

BA

BACT

BAER

BARC

BMPs

BRC

CAA

CCF

CDC

CEQ

CFR

CFS

CMAI

CWA

CWD

DBH

DEIS

DPS

DSD

EA

ECA

EHE 

EIS

EPA

ESA 

FACTS

FEIS

FMU

FP

FRCC

FSH

FSM

FWS/USFWS

GAO

GIS

HD

HFRA

HG

HQ

HSI

HUC

ICBEMP

ID Team

IMPLAN

IMPROVE

INFISH

American Indian Religious Freedom Act

Alternative

Area of Potential Effect

Administrative Rule of Montana

Archaeological Resource Protection Act

All-terrain Vehicle (also OHV or ORV)

Basal Area; refers to forest management

Biological Assessment; refers to ESA

Best Available Control Technology

Burned Area Emergency Response

Burned Area Reflectance Classification

Best Management Practices

Bitterroot Restoration Committee

Clean Air Act

100 Cubic Feet

Centers for Disease Control

Council on Environmental Quality

Code of Federal Regulation

Cubic Feet Per Second

Culmination of Mean Annual Increment

Clean Water Act

Coarse Woody Debris

Diameter at Breast Height (at 4.5ft.)

Draft Environmental Impact Statement

Distinct Population Segment

Detrimental Soil Disturbance

Environmental Assessment

Equivalent Clearcut Area

Elk Habitat Effectiveness

Environmental Impact Statement

Environmental Protection Agency

Endangered Species Act

Forest Activity Tracking System

Final Environmental Impact Statement

Fire Management Units

Forest Plan

Fire Regime Condition Class

Forest Service Handbook 

Forest Service Manual

United States Fish & Wildlife Service

General Accounting Office

Geographical Information System

Hunting District

Healthy Forests Restoration Act

Habitat Group

Hazard Quotient

Habitat Suitability Index

Hydrologic Unit Code

Interior Columbia Basin Ecosystem Mgmt Project

Interdisciplinary Team

Employment and Income Impacts Model 

Interagency Monitoring Protected Visual 

Environments

Inland Native Fish Strategy

KOC

LAU

LC50

LCAS

LEO

LMUs

LTB

LTSP

LWD

MA

MBF

MDEQ/DEQ

MIS

MMBF

MNHP

MTFWP

MTSHPO

MVUM

NAAQS

NAGPRA

NEPA

NFDRS

NFMA

NFS

NFSR

NHPA

NOEC

NOEL

NRCS

NRHP

NRM

NTU

OHV

ORV

OSHA

PF

PIBO

PM2.5

PM10

PNV

PSD

R1 SQS

RAs

RARE II

RAVG

RfD

RHCA

RMO

RNA

ROS

RUPs

SERA

Soil Absorption Coefficient

Lynx Analysis Unit

Lethal Concentration

Lynx Conservation Assessment Strategy

Law Enforcement Officer

Landtype Mapping Units

Lake Tahoe Basin

Long-term Site Productivity Project

Large Woody Debris

Management Area

Thousand Board Feet

Montana Department of Environmental Quality

Management Indicator Species

Million Board Feet

Montana Natural Heritage Program

Montana Fish, Wildlife & Parks

Montana State Historic Preservation Office

Motor Vehicle Use Map

National Ambient Air Quality Standards

Native American Graves Protection and 

Repatriation Act 

National Environmental Policy Act

National Fire Danger Rating System

National Forest Management Act

National Forest System

National Forest System Road

National Historic Preservation Act

No Observed Effect Concentration

No Observed Effect Level

Bitterroot National Forest Soil Survey

National Register of Historic Places

Northern Rocky Mountains

Non-turbulent Unit

Off-highway Vehicle

Off-road Vehicle

Occupational Safety & Health Administration

Project File

PACFISH/INFISH Biological Opinion

Fine Particulate Matter

Coarse Particulate Matter

Present Net Value

Prevention of Significant Deterioration

Region 1 Soil Quality Standards

SERA Human Health and Ecological Risk 

Assessments

Roadless Area Review and Evaluation

Remote Sensing Program

Reference Dosage

Riparian Habitat Conservation Area

Riparian Management Objective

Research Natural Area

Recreation Opportunity Spectrum

Restricted Use Pesticides

Syracuse Environmental Research Associates
Appendix D - Glossary

Lower West Fork Project Final EIS D-21

SGR

SHPO

SIO

SIP

SIS

SMZ

SWCPs

TEA

TES

TLM

TMDL

TSA

TSMRS

μg/m3

USDA

USDI

USFS

USFWS

VQO

VRU

WEPP

WQLS

WUI

Subsoiling Grapple Rake

State Historic Preservation Officer

Scenic Integrity Objectives

State Implementation Plans

Smoke Impact Sheet

Streamside Management Zone

Soil and Water Conservation Practices

Transaction Evidence Appraisal

Threatened and Endangered Species

Track Line Machine

Total Maximum Daily Loads

Timber Sale Administrator

Timber Stand Management Record System

Microgram per cubic meter

United States Department of Agriculture

United States Department of Interior

United States Forest Service

USDI-Fish & Wildlife Service

Visual Quality Objectives

Vegetation Response Unit

Water Erosion Prediction Project

Water Quality Impaired Streams

Wildland Urban Interface
Appendix E - List of Preparers

Lower West Fork Project Final EIS E-1

APPENDIX E

LIST OF PREPARERS

Chip Britting, USDA Forest Service, Bitterroot National Forest, Forestry Technician

Contribution: Timber and Logging Systems 

Education: BS in Natural Resources with a Forestry major from the University of Michigan

Experience: Forest Service- 33 years primarily in Timber Management with some career experience in 

silviculture and wildlife.

Joe Butsick, USDA Forest Service, Bitterroot National Forest, Resource Assistant Recreation and 

Special Uses

Contribution: Editor

Education: BS in Wildlife Management from the University of Wisconsin – Stevens Point

3 years Forestry Science/Wildlife Management at Penn State University

Experience: Forest Service – 28 years primarily in timber, range, botany, fisheries and wildlife, NEPA

Dave Campbell, USDA Forest Service, Bitterroot National Forest, West Fork District Ranger

Contribution: Leadership advice and liaison

Education: B.S. in Recreation Administration and Forestry from Colorado State University

Experience: Forest Service – 32 years silviculture, District Ranger

David Fox, USDA Forest Service, Bitterroot National Forest, Fire and Fuels Specialist

Contribution: Fire Behavior, Fuels, and Air Quality

Education: Bachelor of Science in Forest Management, The University of Montana

Associate Degree in Applied Science in Forest Recreation Management, Paul Smith's 

College

Experience: Forest Service – 7 years forestry, fuels and fire management

Deb Gale, USDA Forest Service, Bitterroot National Forest, Wilderness/Trails Program Manager

Contribution: Wilderness, Inventoried Roadless Areas, and Trails 

Education: Bachelor of Science in Forestry Management from Oregon State University. 

Bachelor of Science in Resource Recreation Management from Oregon State University 

Experience: Forest Service – 21 years in recreation, trails, timber, minerals, special uses, and wilderness

management.

Sara Grove, USDA Forest Service, Bitterroot National Forest, Interdisciplinary Team Leader

Contribution: Interdisciplinary Team Leader

Education: Bachelor of Arts in Biological Sciences from San Jose State University. 
Appendix E - List of Preparers

E-2 Lower West Fork Project Final EIS 

Master of Science in Forest Resources from University of Idaho

Experience: Forest Service – 20 years in pest management, timber, range, and watershed management

and NEPA analysis.

Cheri Hartless, Certified Silviculturist

Contribution: Vegetation Management

Education: Bachelor of Science in Forest Management from University of Montana. 

Bachelor of Science in Fire Ecology from University of Montana

Certified Silviculturist since 2004, Program of Advanced Studies in Silviculture (PASS) 

2000, and Continuing Education in Ecosystem Management (CEEM) 2001.

Experience: Forest Service – 20 years in silviculture, timber management, fire ecology, and Forest 

Inventory and Analysis (FIA).

Stu Hoyt, USDA Forest Service, Bitterroot National Forest, Acting District Fire Management Officer

Contribution: Fire and Fuels analysis

Education: Bachelor of Science in Forest Management from Unity College.

Experience: Forest Service – 30years in timber, fire, and recreation management.

Mike Jakober, USDA Forest Service, Bitterroot National Forest, Fish Biologist

Contribution: Fisheries, Project coordination

Education: Master of Science in Fish and Wildlife Management from Montana State University

Bachelor of Science in Wildlife Biology from the University of Montana

Experience: Forest Service – 15 years as a Fish Biologist

Abby Kirkaldie, USDA Forest Service, Bitterroot National Forest, GIS Specialist

Contribution: GIS Maps and Analysis

Education: Bachelors of Science in Forest Resource Management from University of Montana

1 yr study of GIS and Cartography at Western Washington University

Experience: Forest Service – 5 yr in GIS; WY State Geological Survey – 5 years in GIS; WA State DNR 

– 4 years in wildlife/forestry; BC Environment – 1 yr in wildlife 

Cole Mayn, USDA Forest Service, Northern Region, Regional Office, Soil Scientist

Contribution: Soils Analysis

Education: Master of Science in Land Rehabilitation, Minor in Soils from Montana State University.

Bachelor of Science in Environmental Engineering, Montana Tech of the University of 

Montana.

Experience: Forest Service – 6 years in soils and watershed management; Private Industry – 5 years in 

soils, land rehabilitation, and environmental engineering.
Appendix E - List of Preparers

Lower West Fork Project Final EIS E-3

Lee McAlpine, USDA Forest Service, Bitterroot National Forest, Forester

Contribution: Silviculture

Education: Bachelor of Science in Forest Management from Humboldt State University. 

Post-graduate studies in Forest Engineering and Silviculture from Oregon State University, 

and in Silviculture from University of Washington. Non-matriculated post-graduate studies 

in Forest Ecology, Wildlife Management, and Fuels Management from Clemson University, 

University of Virginia Polytechnic Institute, and Colorado State University. Certificate of 

Completion from the Fire Use Training Academy in Albuquerque, New Mexico.

Experience: Forest Service and National Park Service, six years experience in Fire/Fuels/Air Resources.

Linda Pietarinen, USDA Forest Service, Bitterroot National Forest, Botanist

Contribution: TES Plants and Noxious Weeds

Education: Bachelor of Science in Biology from the University of South Carolina. 

Completed 2 years of graduate work in Botany and Environmental Studies at the University 

of Montana.

Experience: Forest Service – 18 years in botany

Jacob Pintok, USDA Forest Service, Bitterroot National Forest, Transportation Engineer

Contribution: Roads Analysis, road condition surveys on proposed haul routes

Education: Bachelor of Science in Construction Engineering Technology, Montana State University. 

Completed 2 years of graduate work in Botany and Environmental Studies at the University 

of Montana.

Experience: Forest Service – 7 years in transportation engineering

David Romero, USDA Forest Service, Bitterroot National Forest, Wildlife Biologist

Contribution: Wildlife Biology

Education: Bachelor of Science in Wildlife Science from New Mexico State University.

Experience: Forest Service – 10 years in wildlife biology

Andrea Shortsleeve, USDA Forest Service, Bitterroot National Forest, Wildlife Biologist

Contribution: Wildlife Biology

Education: Master of Science in Human Dimensions of Natural Resources from Colorado State 

University

Bachelor of Agricultural and Environmental Science in Wildlife Biology from McGill 

University, Montreal, Canada.

Experience: Forest Service – 4 months in wildlife biology, 2 seasons wildlife biology intern; BLM – 3 

years in fire, fuels, and wildlife

Keith Stockmann, USDA Forest Service, Northern Region, Regional Office, Regional Economist

Contribution: Economic Analysis

Education: Doctorate in Applied Wildland Economics from the University of Montana
Appendix E - List of Preparers

E-4 Lower West Fork Project Final EIS 

Masters of Science in Environmental Studies, Interagency Grizzly Bear Recovery, 

University of Montana

Bachelor of Arts in Economics from Colby College, Maine

Experience: Forest Service – 2 years Regional Economist, Northern Region; 10 years with various land 

and wildlife management non-profit groups, Interagency Grizzly Bear Recovery, and as 

Wilderness Ranger

Marilyn Wildey, USDA Forest Service, Bitterroot National Forest, Hydrologic Technician

Contribution: Watershed

Education: Bachelor of Science in Education from Boise State University. 

Graduate course work in Hydrology from the University of Montana

Experience: Forest Service – 24 years in hydrology, recreation and timber

Mary Horstman Williams, USDA Forest Service, Bitterroot National Forest, Heritage Program 

Manager

Contribution: Heritage Resources

Education: Bachelor’s and Master’s from the University of Montana 1989, with specialization in 

history of Montana and the West, and an emphasis on mining history and land use in the 

Northern Rockies. Graduate work in archaeology and cultural resource management.

Experience: 26 years in cultural resource management and historical research.
Appendix F – Forest Plan Amendment

Lower West Fork Project Final EIS F-1

APPENDIX F

FOREST PLAN AMENDMENT

Implementation of the preferred Alternative requires site-specific forest plan amendments to the Bitterroot 

Forest Plan (1987) {FEIS p. 1-12 to 1-15}. Therefore, an amendment will be needed that will modify the 

following Forest Plan standards specifically as they relate to the Lower West Fork Project.

Ø Elk habitat effectiveness standard

Ø Forest-wide thermal cover standard.

Ø Coarse woody debris standards.

The need for these amendments to meet the purpose and need of the Lower West Fork project was 

disclosed in the Notice of Intent (12/2007). This Appendix contains information that compliments the 

coarse woody debris, thermal cover, and elk habitat effectiveness analyses in the FEIS. 

Forest Service Manual (FSM) 1926.51 provides direction for determining what constitutes a “significant 

amendment” under NFMA. Based on this guidance, these site-specific forest plan amendments are not 

significant because they will not individually or cumulatively significantly alter the long-term relationship 

between levels of multiple-use goods and services originally projected; and, they will not have an important 

effect on the entire land management plan, or affect land and resources throughout a large portion of the 

planning area during the planning period. The amendments modify standards and guidelines, specific to 

the Lower West Fork project. Therefore, they are not a long term change in the plan. The Bitterroot Forest 

Plan is currently being revised. The public has been notified of these amendments throughout the NEPA 

process. 

The amendment analyses are organized to:

Ø Describe the amendment element

Ø Explain the purpose and the need for the amendment

Ø Describe the direct, indirect and cumulative effects of the amendment

Ø Apply the Forest Service Manual criteria for assessing whether or not the amendment is significant

Ø Display the conclusion on significance or non-significance. 

ELK HABITAT EFFECTIVENESS

SITE-SPECIFIC AMENDMENT PROPOSED FOR THIS STANDARD

The Bitterroot Forest Plan includes the following resource and Management Area (MA) standards relevant 

to elk habitat effectiveness and the Lower West Fork project:

Forest-wide wildlife resource standards: (USDA Forest Service 1987, pp. II-21, e (14))

Ø Manage roads through the Travel Plan process to attain or maintain 50 percent or higher elk habitat 

effectiveness (Lyon, 1983) in currently roaded third order drainages. Drainages where more than 

25 percent of roads are in place are considered roaded. Maintain 60 percent or higher elk habitat 

effectiveness in drainages where less than 25 percent of the roads have been built. 

MA 1, 2, 3a, 3b, 3c, 8a: (USDA Forest Service 1987, pp. III-4, c (4); III-10, c (4); III-17, c (4); III-25, 

c (11); III-31, c (4); III-59, c (2))

Ø Maintain elk habitat effectiveness through road closures as specified in the Forest-wide standards 

in Chapter II (Lyon, 1983). 

The site-specific elk habitat effectiveness (EHE) standard for the Lower West Fork project would read:

All roaded 3rd order drainages in the Lower West Fork analysis area will attain 

or maintain 50 percent or higher elk habitat effectiveness (Lyon 1983) except 
Appendix F – Forest Plan Amendment

F-2 Lower West Fork Project Final EIS 

in five drainages. Elk habitat effectiveness will be maintained or improved in 

the five 3rd order drainages as shown below:

PURPOSE AND NEED OF ELK HABITAT EFFECTIVENESS STANDARD AMENDMENT

Elk Habitat Effectiveness in Five 3rd Order Drainages in the Lower West Fork Analysis Area

The proposed standard amendment is intended to acknowledge that the EHE standard cannot be met 

without closing access trailheads or roads needed for forest management access in five 3rd order drainages 

in the Lower West Fork analysis area. In this analysis area, the proposed standard would replace the 

various management area standards in the 1987 Forest Plan (USDA Forest Service 1987, pp. III-4, c (4); 

III-10, c (4); III-17, c (4); III-25, c (11); III-31, c (4); III-59, c (2)). 

Amendment Purpose

Pertinent Forest Plan Goals (USDA Forest Service 1987, pp. II-3)

Intent of the Plan

Ø Provide habitat to support viable populations of native and desirable non-native wildlife and fish.

Ø Design transportation systems and road management programs that are responsive to public 

concerns and protect resource goals.

Pertinent Forest Plan Objectives (USDA Forest Service 1987, pp. II-5)

Ø Maintain habitat to support viable populations of wildlife species.

Ø Cooperate with the State of and Montana to maintain the current level of big-game hunting 

opportunities.

This site-specific amendment is needed in the Lower West Fork analysis area as the EHE standard cannot 

be met in five, 3rd order drainages without conflicting with additional resource goals and objectives. In 

02e424-1, 02f427-3, 02449-1, 02h450-2, or 02i450-1 drainages, 50 percent EHE cannot be met without 

closing road that access trailheads or are needed for forest management purposes. 

Need for the Amendment

DIRECT,INDIRECT, AND CUMULATIVE IMPACT OF LOWER WEST FORK ELK 

HABITAT EFFECTIVENESS AMENDMENT

Direct and Indirect Effects

Under this amendment, none of the drainages inside of the Lower West Fork analysis area would decrease 

in elk habitat effectiveness. All areas will either maintain the current EHE level or move towards meeting 

the Forest Plan standard. No new permanent roads will be created or opened as a result of this amendment, 

and we will still be meeting related Forest Plan Goals and Objectives. We have added an elk security 

analysis (Hillis et al. 1991) to our environmental analysis protocol that has proven to be a better tool than 

elk habitat effectiveness analysis for achieving the Forest Plan objective to maintain elk populations and 

hunting season opportunities in cooperation with Montana Fish, Wildlife and Parks.

Cumulative Effects

The EHE requirements and levels for the Lower West Fork project are discussed in Section 3.8.5.C in the 

FEIS, and displayed in Table 3.8-5 of the FEIS. The understanding of road density and its influence on

3rd Order Drainage

02e424-1

Elk Habitat Effectiveness 

43 %

02f427-3 47 %

02h449-1 43 %

02h450-2 44 %

02i450 -1 48 %
Appendix F – Forest Plan Amendment

Lower West Fork Project Final EIS F-3

EHE has changed with more research and strict adherence to road density may not be the most important 

factor in providing effective elk habitat. The amended EHE requirements for this project will involve less 

than 0.1 percent of the 3rd order drainages on the Bitterroot National Forest. Since the establishment of the 

Forest Plan in 1987, four other similar site-specific amendments of the EHE standard have been made:

The cumulative effect of amending the EHE standard in the Lower West Fork analysis area in addition to

these previous EHE amendments would be imperceptible at the Forest scale. Many of the 3rd order 

drainages are within 10 percent of the EHE standard and the Bitterroot Valley elk population is stable. The 

MTFWP rates elk security in HD 250 as good to excellent because of the rugged terrain, road closures, and 

roadless and Wilderness areas that provide opportunities to evade hunters. Bitterroot Forest Plan objective 

and goals would continue to be met. 

None of the ongoing or reasonably foreseeable future projects listed in Appendix B would further reduce

EHE in any of the third order drainages within the analysis area. We have added an elk security analysis 

(Hillis et al. 1991) to our environmental analysis protocol that has proven to be a better tool than elk habitat 

effectiveness analysis for achieving the Forest Plan objective to maintain elk populations and hunting 

season opportunities in cooperation with Montana Fish, Wildlife and Parks. In summary, the proposed 

actions, in combination with past and reasonably foreseeable future actions in this analysis area, are not 

expected to cumulatively degrade the habitat effectiveness for elk.

Cumulatively, by implementing this site-specific standard for elk habitat effectiveness, the Lower West 

Fork project area is expected to have appropriate levels of secure habitat for elk, over time, fully supporting 

the Forest goals and objectives. 

There is no perceptible cumulative effect of this modification, in conjunction with the site-specific thermal 

cover and coarse woody debris modifications to the Forest Plan proposed in this project.

APPLICATION OF FSM 1926.51 “NOT SIGNIFICANT” CRITERIA

Our determination of whether this amendment is significant was done using the process in FSM 1926.51. 

The handbook states that changes to the land management plan that are not significant can result from four 

specific situations. This site-specific amendment is compared to those situations below: 

Year Number of 3rd

Order Drainages Environmental Document Ranger District

1997 2 Camp Reimel EA Sula

2001 3 Burned Area Recovery EIS Darby, Sula, West Fork

2002 5 Slate Hughes Watershed Restoration & Travel Management West Fork

2008 5 Trapper-Bunkhouse EIS Darby
Appendix F – Forest Plan Amendment

F-4 Lower West Fork Project Final EIS 

CONCLUSION -- SIGNIFICANCE/NON-SIGNIFICANCE

Based on consideration of the four factors identified in FSM 1926.51, and considering the Forest Plan in its 

entirety, the adoption of the elk habitat effectiveness amendment to the Bitterroot National Forest Plan is 

not significant. This amendment is fully consistent with, but further refines and clarifies the means to 

achieve, current Forest Plan goals and objectives.

THERMAL COVER

SITE-SPECIFIC AMENDMENT PROPOSED FOR THIS STANDARD

The Bitterroot Forest Plan includes the following Forest-wide resource standard relevant to thermal cover 

and the Lower West Fork project:

1987 Forest Plan Record of Decision (USDA Forest Service 1987, p. 8)

Ø “Winter range will be managed to provide diversity of forage and hiding cover with at least 25 

percent of the area in thermal cover at all times.” 

The site-specific thermal cover standard to be applied for the Lower West Fork project would read:

“Thermal cover on winter range will be treated in the Lower West Fork analysis area

to the extent needed to protect the overstory from loss due to fire in parts of 20 units 

(Fig. F-1).”

Changes to the Land Management Plan That are 

Not Significant Elk Habitat Effectiveness Standard Amendment

1. Actions that do not significantly alter the 

multiple-use goals and objectives for long-term land 

and resource management.

The elk habitat effectiveness amendment does not 

alter the multiple-use goals and objectives for longterm land and resource management. 

The amendment affects a small area of the Bitterroot 

National Forest (about 1.5 percent). This shortterm, site-specific project amendment will have no 

effect on Forest Plan objectives or outputs. 

2. Adjustments of management area boundaries or 

management prescriptions resulting from further onsite analysis when the adjustments do not cause 

significant changes in the multiple-use goals and 

objectives for long-term land and resource 

management. 

The elk habitat effectiveness amendment does not 

adjust management area boundaries. 

3. Minor changes in standards and guidelines.

The amendment reduces elk habitat effectiveness 

between 2 and 7% below Forest Plan standard in 5 

of 19 3rd order drainages in the Lower West Fork 

Analysis area. This reduction is a minor change to 

management area standards when considered in the 

context of surrounding drainages with optimum elk 

habitat effectiveness. Over the whole analysis area, 

road densities vary between 1.2 and 2.2 mi/mi2 in 

Alternative 2 to 1.0 and 2.0 mi/mi2 in Alternative 3. 

4. Opportunities for additional projects or activities 

that will contribute to achievement of the 

management prescription.

The elk habitat effectiveness amendment allows 

access to forest areas that are needed for 

management requirements.
Appendix F – Forest Plan Amendment

Lower West Fork Project Final EIS F-5

Figure F- 1: Winter Range Thermal Cover and Proposed Treatment Units in the Lower West Fork Analysis Area.
Appendix F – Forest Plan Amendment

F-6 Lower West Fork Project Final EIS 

PURPOSE AND NEED OF THERMAL COVER STANDARD AMENDMENT

This proposed site-specific standard amendment is intended to apply the best available science to the Lower 

West Fork project’s thermal cover design and adapt to changes that have occurred on the landscape in 

support of Forest Plan and project goals and objectives. The proposed, ecologically-based standard would 

replace, for this project, the various management area standards in the 1987 Forest Plan ROD (USDA 

Forest Service 1987, p. 8). 

Amendment Purpose

Pertinent Forest Plan Goals (USDA Forest Service 1987, pp. II-3)

Intent of the Plan

Ø Provide habitat to support viable populations of native and desirable non-native wildlife and fish.

Pertinent Forest Plan Objectives (USDA Forest Service 1987, pp. II-5)

Ø Maintain habitat to support viable populations of wildlife species.

Ø Cooperate with the State of and Montana to maintain the current level of big-game hunting 

opportunities.

Historically, low intensity fires burned more area in habitat type groups A and B and impeded the 

development of thermal cover on elk winter range. Decades of fire suppression increased thermal cover, 

which decreased big game forage. The relatively small scale of the timber harvest together with fire 

exclusion allowed the development of more thermal cover than was typical in these habitat types, creating 

an overstory that allowed large, uncharacteristic fires to burn. In the last decade, fires have reduced 

thermal cover on winter range by 54 percent in the Lower West Fork analysis area. This proposed sitespecific amendment recognizes and addresses the conflicting nature of the Forest Plan’s fuels and fire 

protection goals, objectives and standards for the WUI and the overlapping winter range thermal cover 

standard defined in the Forest Plan Record of Decision (1987, pg. 8).

Need for the Amendment

DIRECT,INDIRECT, AND CUMULATIVE IMPACT OF LOWER WEST FORK THERMAL 

COVER AMENDMENT

Direct and Indirect Effects

There will be a decrease in the amount of thermal cover; however, it is not expected to affect the elk 

population in a way that would compromise their viability. All units in winter range in the Lower West 

Fork project area would be thinned only to the extent needed to protect the overstory from loss in a fire. 

Protecting the overstory would ensure the presence of thermal cover in the future. Currently, the thermal 

cover in winter range is 4% below the standard. The proposed amendment would bring the level of thermal 

cover to only 7% below the standard. In HD 250, thirty-five percent of the area (250 miles2

) is winter 

range; 86 percent of which is on public land. Elk appear to use winter range on private land 

disproportionately more than public land (Montana Statewide Elk Management Plan 2004). 

Cumulative Effects

Research conducted since the Forest Plan was signed questions the necessity of thermal cover for survival 

of wintering elk (Cook, et al. 1998). Researchers found “no significant, positive effect of thermal cover on 

the condition of elk during any of the six experiments. In contrast, dense cover provided a costly energetic 

environment, resulting in significantly greater over-winter mass loss, fat catabolism, and (in one winter) 

mortality.” Wintering elk survived and retained body weight better in open areas than in thermal cover. 

For this reason, whether thermal cover is necessary for individual elk survival or elk population viability 

seems open to question. For additional information, refer to Chapter 3, Section 3.8.5.C.
Appendix F – Forest Plan Amendment

Lower West Fork Project Final EIS F-7

No reasonably foreseeable actions in the analysis area would further reduce thermal cover in the Lower 

West Fork analysis area. Outside of the analysis area, three percent of the winter range thermal cover 

would be treated in the Trapper-Bunkhouse project. Trapper-Bunkhouse treatments are expected to reduce 

winter range thermal cover to six percent. Though the Lower West Fork project maintains more thermal 

cover than that in Trapper-Bunkhouse (17% in Alternative 2 and 20% in Alternative 3), it would not 

compensate for the low amount of thermal cover in Trapper-Bunkhouse. However, thermal cover on 

winter range does not appear to be as important to elk winter survival as was once thought (Cook et al. 

1998). Treatments proposed in the Lower West Fork project would maintain open forest canopies and 

improve forage productivity in the understory, which may offset the loss of thermal cover (Lehmkuhl et al. 

2002, Poole and Mowat 2005). 

Cumulatively, by implementing this site-specific standard for thermal cover, the Lower West Fork project 

area is expected to have appropriate levels of thermal cover on winter range, over time, and fully support 

the Forest goals and objectives. 

There is no perceptible cumulative effect of this modification, in conjunction with the site-specific coarse 

woody debris and elk habitat effectiveness modifications to the Forest Plan proposed in this project.

APPLICATION OF FSM 1926.51 “NOT SIGNIFICANT” CRITERIA

Our determination of whether this amendment is significant was done using the process in FSM 1926.51. 

Changes to the Land Management Plan That are Not 

Significant Thermal Cover Standard Amendment

1. Actions that do not significantly alter the multiple-use 

goals and objectives for long-term land and resource 

management.

The thermal cover amendment does not alter the 

multiple-use goals and objectives for long-term land and 

resource management. The amendment will continue to 

maintain quality elk habitat by replacing the current 

Forest Plan Standard with one developed based on recent 

studies.

The amendment affects a small area of the Bitterroot 

National Forest (about 1.5 percent). This short-term, sitespecific project amendment will have no effect on Forest 

Plan objectives or outputs. 

2. Adjustments of management area boundaries or 

management prescriptions resulting from further on-site 

analysis when the adjustments do not cause significant 

changes in the multiple-use goals and objectives for longterm land and resource management. 

The thermal cover amendment does not adjust 

management area boundaries. It provides for more sitespecific, ecologically-based management prescription by 

preventing massive canopy loss by thinning out 

overgrown forest stands.

3. Minor changes in standards and guidelines.

The thermal cover amendment is a minor change to 

management area standards. At most, the project would 

reduce thermal cover to 7% below standard. Current 

research indicates that thermal cover is not as important 

to wintering elk as early research indicated. 

4. Opportunities for additional projects or activities that 

will contribute to achievement of the management 

prescription.

Developing thermal cover requires time and maintaining 

forest cover over time. The thermal cover amendment 

allows thinning in thermal cover that improves the 

probability of retaining the forest canopy in a fire. Fire is 

more likely to burn at lower intensities in the thinned 

stands. No other projects are scheduled in the Lower 

West Fork analysis area that would reduce or enhance 

thermal cover development. Though not meeting the 

25% requirement, this project will meet the Forest Plan 

goals and objectives related to elk (viable populations and

cooperating with State goals). These are the goals that the 

25% requirement was intended to support.
Appendix F – Forest Plan Amendment

F-8 Lower West Fork Project Final EIS 

The handbook states that changes to the land management plan that are not significant

Conclusion -- Significance/Non-Significance

can result from four 

specific situations. This site-specific amendment is compared to those situations above: 

Based on consideration of the four factors identified in FSM 1926.51, and considering the Forest Plan in its 

entirety, the adoption of the thermal cover amendment to the Bitterroot National Forest Plan is not 

significant. This amendment is fully consistent with, but further refines and clarifies the means to achieve, 

current Forest Plan goals and objectives.

COARSE WOODY DEBRIS

SITE-SPECIFIC AMENDMENT PROPOSED FOR THIS STANDARD

The Bitterroot Forest Plan includes the following Management Area (MA) standards relevant to coarse 

woody debris and the Lower West Fork project:

MA 1, 2, 3a: (USDA Forest Service 1987, pp. III-6, f (4); III-12, f (3); and III-19, f (4))

Ø Site preparation methods will assure the retention of modest levels of organic matter, including 

woody materials 8 inches or less in diameter, to provide nutrient and ectomycorrhizal levels 

necessary for maintaining growth rates; while still providing an adequate mineral base for seed 

germination and reduction of grass competition. On dry and harsh sites, at least 10 to 15 tons per 

acre of residual debris is needed (Harvey, et al 1981a & 1981b; Harvey, 1982). 

MA 2 (USDA Forest Service 1987, p. iII-13, j (2))

Ø Natural and activity fuels will be treated to reduce slash depth below 1 1⁄2 feet to provide for biggame movement. About 25 tons/acre of down trees larger than 6-inch diameter will be left for 

nongame habitat if available.

The site-specific coarse woody debris standard to be applied for the Lower West Fork project would read:

“To maintain soil productivity and wildlife habitat while meeting fuel reduction purpose 

and needs, coarse woody debris (material greater than 3 inches in diameter) will be left from 

designated leave trees, both standing and down, and from breakage of limbs and broken tops 

that will occur during harvest at or above the minimum levels identified in the following 

table. Material will be evenly distributed on each acre. At least minimum levels will also be 

retained after burn treatments. Fire Groups are described in the DEIS, Chapter 3, Section 

3.2-3 A.

Proposed Coarse Woody Debris Standard by Fire Group

Wood larger than 15 inches in diameter will not be intentionally ignited during hand lighting. It is 

understood that once the fire is lit by hand crews, the fire may burn into large CWD and combust various 

pieces.”

PURPOSE AND NEED OF WOODY DEBRIS STANDARD AMENDMENT

This proposed site-specific standard amendment is intended to apply the best available science to the Lower 

West Fork project’s coarse woody debris design in support of Forest Plan and project goals and objectives. 

Amendment Purpose

Fire Group Coarse Woody Debris

2, 4 5-10 tons/acre

6 10-20 tons/acre

7, 8, 9 8-24 tons/acre
Appendix F – Forest Plan Amendment

Lower West Fork Project Final EIS F-9

The proposed, ecologically-based standard would replace, for this project, the various management area 

standards in the 1987 Forest Plan (USDA Forest Service 1987, pp. III-6, f(4); III-12, f (3); and III-19, f(4)). 

Pertinent Forest Plan Goals (USDA Forest Service 1987, pp. II-3, II-4)

Intent of the Plan

Ø Maintain soil productivity

Ø Design fire management programs that are consistent with other resource goals (Appendices K and 

M)

Pertinent Forest Plan Objectives (USDA Forest Service 1987, pp. II-6, II-7)

Ø Design management activities to maintain soil productivity

Since the Forest Plan was signed, additional science has become available regarding the amount of coarse 

woody debris that would be expected in different habitat type groups (Graham et al., 1994; Brown et al, 

2000), which provides more refined guidelines for meeting the Forest Plan goals and objectives. The 

amounts prescribed in the Forest Plan are sometimes contradictory to each other (i.e. 10 to 15 tons/acre in 

one standard and 25 tons/acre in another; sometimes referring to the same piece of ground). In addition, to 

reduce fire intensity (flame length and rate of spread), heavy amounts of coarse woody debris should not be 

left in stands in the Lower West Fork project area. 

Need for the Amendment

DIRECT,INDIRECT, AND CUMULATIVE IMPACT OF LOWER WEST FORK WOODY 

DEBRIS AMENDMENT

Direct and Indirect Effects

All harvest prescriptions for the Lower West Fork project would leave a portion of the existing stand on the 

site. Yarding will be either whole tree or leave tops attached. Coarse woody debris (CWD) (material 

greater than 3 inches in diameter) will be left from designated leave trees, both standing and down, and 

from breakage of limbs and broken tops that will occur during harvest. The amounts listed for each Fire 

Group (see table below) will maintain future soil productivity. Information concerning coarse woody 

debris is outlined in PF-FIRE-027.

Coarse Woody Debris Requirements for Soil Productivity

The proposed fuel treatments would to leave slash on the ground through the winter and into late 

summer/fall before prescribed burning will be completed. This will provide opportunity for the nutrients in 

the slash to be leached into the soil. 

Cumulative Effects

The CWD requirements for the Lower West Fork project are discussed in Section 3.5.4.B in the DEIS, and 

displayed in Table 3.5-5 of the DEIS. The CWD requirements are based on the most current science which 

varies from the amounts shown in the current Forest Plan. The amended CWD requirements for this 

project will encompass less than 0.1 percent of the Bitterroot National Forest (based on maximum 

treatment area of 2,494 acres in Alternative 2). Since the establishment of the Forest Plan in 1987, two 

other forest plan allowances have been made which include the Burned Area Recovery Project in 2001 and 

the Middle East Fork Project in 2006. The Burned Area Recovery CWD amendment was needed to 

Fire Group CWD

2 and/or 4 = Warm, Dry Ponderosa Pine and Douglas-fir 

Habitat Types 5 to 10 tons/acre

6 = Cool, Dry and Moist Douglas-fir Habitat Types 10 to 20 tons/acre

7, 8, and/or 9 = Cool Lodgepole Pine and Lower Subalpine 

Fir Habitat Types 8 to 24 tons/acre
Appendix F – Forest Plan Amendment

F-10 Lower West Fork Project Final EIS 

address soil and site productivity concerns related to salvage following large wildfires and was also based 

on similar current science. Burned Area Recovery treatments comprised approximately 0.6 percent of the 

Bitterroot National Forest. The Middle East Fork project amendment (0.3 percent of the forest) was needed 

to ensure CWD retention for fuel reduction treatments were based on current science. Additional 

amendments have been included for the recent Trapper Bunkhouse FEIS and Haacke Claremont EA. 

These amendments in combination with Alternative 2 of this project (maximum treatment area) 

cumulatively amount to approximately 1.5 percent of the Bitterroot National Forest. The modifications of 

the CWD requirements for this project will not have appreciable cumulative effects at the site or forest 

scale.

Cumulatively, by implementing this site-specific standard for CWD, the Lower West Fork project area is 

expected to have appropriate levels of CWD by fire group, over time, fully supporting the Forest goals and 

objectives. 

There is no perceptible cumulative effect of this modification, in conjunction with the site-specific thermal 

cover and elk habitat effectiveness modifications to the Forest Plan proposed in this project.

APPLICATION OF FSM 1926.51 “NOT SIGNIFICANT” CRITERIA

Our determination of whether this amendment is significant was done using the process in FSM 1926.51. 

The handbook states that changes to the land management plan that are not significant

Conclusion -- Significance/Non-Significance

can result from four 

specific situations. This site-specific amendment is compared to those situations below: 

Based on consideration of the four factors identified in FSM 1926.51, and considering the Forest Plan in its 

entirety, the adoption of the coarse woody debris amendment to the Bitterroot National Forest Plan is not 

significant. This amendment is fully consistent with, but further refines and clarifies the means to achieve, 

current Forest Plan goals and objectives.

Changes to the Land Management Plan That are Not 

Significant Coarse Woody Debris Standard Amendment

1. Actions that do not significantly alter the multiple-use 

goals and objectives for long-term land and resource 

management.

The coarse woody debris amendment does not alter the 

multiple-use goals and objectives for long-term land and 

resource management. The amendment will continue to 

work toward maintaining soil productivity by replacing 

the current Forest Plan Standard with one developed 

using more recent studies.

The amendment affects a small area of the Bitterroot 

National Forest (about 1.5 percent). This short-term, sitespecific project amendment will have no effect on Forest 

Plan objectives or outputs. 

2. Adjustments of management area boundaries or 

management prescriptions resulting from further on-site 

analysis when the adjustments do not cause significant 

changes in the multiple-use goals and objectives for longterm land and resource management. 

The coarse woody debris amendment does not adjust 

management area boundaries. It provides for more sitespecific, ecologically-based management prescription 

applications by requiring a range of coarse woody debris 

based on habitat types.

3. Minor changes in standards and guidelines.

The coarse woody debris amendment is a minor change 

to management area standards based on more recent 

science.

4. Opportunities for additional projects or activities that 

will contribute to achievement of the management 

prescription.

The coarse woody debris amendment applies more recent 

science to management prescriptions and provides an 

ecological basis for retaining coarse woody debris.
Log Cabin Environmental Consulting, LLC

Email.logcabinec@gmail.com

Website: logcabinec.com

Theresa J. Bla:z.icevich

113 Log Cabin Lane

Stevensville, MT 59870

(406)370-8902

April 6, 2009

Forest Supervisor's Office

1801 North 1"' SI.

Hamilton, MT 59840-3114

Subject: Lower West Fork Project Draft Environmental Impact Statement (DEIS)

Dear Forest Supervisor:

First. I would like to compliment the Forest Service for trying to improve forest health,

fisheries and soil stability on 5,100 acres in the lower West Fork. The majority of this

project appears to be well-planned for the benefit of the forest and wildlife and will have

little impact on the public with the exception of the use of fire. I am concerned that the

Forest Service continues to use prescribed fire, underburns of slash and slash pite

burns. I would like for you to adopt a "no prescribed burns or slash bums or open

burning policy' in Ravalli County.

As a career environmental health specialist, I am concerned about air pollution from any

source. And, I am very concerned that government agencies continue to use open

burning when Ravalli County has been knocking on the door of air quality nonattainment status for several years. I know exceeding the air quality standards for

particulates mainly occurs in the winter months, but recently the air monitoring results

showed unhealthy health effects for hourly air monitoring in March. As you know,

March is the beginning of the open burning season in Ravalli County and many people

do not follow the best available control technology for conducting open burning like the

Forest Service does.

More importantly, I believe that our government should set a good example for the

public by implementing practices that aggressively protect our environment and public

health. Since Ravalli County is near non-attainment status (has exceeded or is close to

exceeding NAAQS for fine particulates for many of the last 5 years) and subject to

inversions in a narrow mountain valley, why should a government agency, or anyone for

that matter, continue to voluntarily burn and cause air pollution.
As a landowner with training in natural resources and wildlife habitat, I believe you can

accomplish your fuel reduction goals without prescribed burning and slash burning. If it

Is manpower you need to harvest and thm the forest, I would be more than willing to

lobby for more forest service funds if volunla!)' burning were to cease. If you wanlto

talk economic stimulus, I"m sure we could create more jobs by cutting the trees and

chipping the slash rather than burning il.

I am also curious why the environmental impact analYSiS did not provide statistics on

how many wildfires were caused by slash piles or prescribed bums or open burning.

Are you really reducing the wildfire potential by burning? Would thinning, harvesting,

composting, chipping or other methods work just as well or beller than burning? Where

is the economic analysis that compares the cost of burning to the cost to our health?

The heallh impacts should not just be an evaluation of hospital visits. It should include

the cost of missed sports workouts, young chitdren with asthma with increased costs of

medicaltreatrnent, young athletes having heart attacks, children without resplrato!)'

disease having bronchitis and having to use inhalers after poor air days, adults with

even mild respirato!)' disease that have to stay inside or miss work when someone is

burning slash or conducting prescribed burns.

If wildfires are started by acts of God beyond our control, we can deal with these as

appropriate, but volunteer burning we can control. Our government agencies can help

us start Ihe long education process that open burning is probably already impacting our

health and will continue to do so, if it continues In the Bitterroot. When we discussed

the air monitoring data and results that exceeded air quality standards for 2004 and

2005, many Ravalli County residents pointed at the Forest Service as the pollution

source. If the Forest Service was not conducting voluntary burns, this would eliminate

the need to defend your position on open burning.

Thank you for the opportunity to comment on the DEIS. Please consider eliminating

prescribed burns and the practice of slash burning. The DEIS does not even mention

that Ravalli County is near non-attainment status for air quality. I believe the OEIS

needs to more seriously address the alternatives to burning with our health in mind.

If you have any questions, please let me know.

~C9~id4C~ Theresa J. Blazicevich
"brentnelsons@netzero

.net" 

<brentnelsons@netzer

o.net> 

05/14/2009 02:34 PM 

To comments-northern-bitterroot-west-fork@fs.fed.us 

cc

Subject Lower West Fork-Comments 

COMMENTS on D.E.I.S. Lower West Fork and how it affects BITTERROOT ADVENTURES 

and other forest visitors. 

ALTERNATIVE 2: 

A. General Comments: 

 Piquette Cr. Rd. 49 with some adjoining roads is the only place in the BNF that BITTERROOT 

ADVENTURES (BA) can take NOVICE ATV riders on a dedicated trail. The dedicated trail is 

wide enough for beginners and eliminates possibility of encounters with full size highway 

vehicles. This is, in fact, an important ingredient for any citizen novice rider, families, and the 

older population. 

 This trail could be considered for over 50" width OHV's, since it is already wide enough for 2 

highway vehicles to pass one another. 

 Trail 49 is short (about 24 miles round trip). It is currently difficult for us (B A) to get a full 

day /6 hour ride using it (about 35-50 miles is needed for a full day). My hope is that there could 

be a loop created--enough to make the ride a little longer. 

 The views of the mountains are excellent. My clients (almost) always comment on that aspect. 

PRECISE COMMENT: 

 Alternative 2 does not appreciably degrade the quality of the ride or the length of it. 

ALTERNATIVE 3: 

A. General Comments: 

 While #3 does not appreciably affect B A's currently permitted routes, it does permanently 

eliminate some possibilities of looping routes together in the future. Loops and destinations are 

very important for a quality forest experience. 

PRECISE COMMENT: 

 Alternative #3 is the LEAST desirable change to Forest Travel Plan for all forest visitors. We 

would, of course, support closures of roads that contribute to stream degradation. But, I do not 

believe wild life is impacted by the roads or the travel on those roads. There is ample roadless 

area in the vicinity. 

REQUEST FOR CONSIDERATION: 

Near the upper end of Road 74606 is a posted (closed) trail that could be considered for a Loop. 

I have not personally walked this path, but have spoken with others who have. The feeling is 

that it could be joined with Trail #49 to created approximately a 5 mile loop. 

BRENT NELSON 

 RCE, Inc. d/b/a 

 BITTERROOT ADVENTURES 

E-MAIL TO: comments-northern-bitterroot-west-fork@fs.fed.us 

 

Lower West Fork-Comments 20 May 2009 

Forest Supervisor’s Office 

Bitterroot National Forest 

1801 North Street Hamilton, 

Montana 59840-3114 

Re: Comments on Proposed Lower West Fork Draft 

Environmental Impact Statement 

 I am submitting the following comments on the Lower West Fork (LWF) Draft EIS 

pursuant to an extension provided to me by Ms. Grove on May 13, 2009.1

 I have 

considered the Forest Service’s four stated “purposes and objectives” for the LWF project 

including: 

1. Reduce Crown Fire Potential - Reduce the area with high potential for standreplacing crown fires in the suitable timber base and wildland urban interface. This will 

reduce the risk from fires harming human life (fire fighters and the public), private 

property, and natural resources in the Lower West Fork analysis area. 

2. Improve Forest Resilience and Provide Forest Products - Provide economic 

opportunity to the community and provide funding opportunities for the activities related 

to reducing sediment contributions, and fuel reduction by capturing economic value of 

insect or disease killed and/or infested trees as well as green tree thinning in plantations 

and at risk areas to improve resiliency to insects and disease. 

 

3. Increase Ponderosa Pine Forest Component and Maintain Larger Size Classes – 

Thin from below to reduce stand competition from shade-tolerant understory trees, 

improve growing space for the larger size classes and favor large, ponderosa pine as the 

dominant site component. 

 

4. Watershed Improvement - Reduce sediment contribution in the West Fork of the 

Bitterroot River from identified high-priority road segments and crossings. Improve 

aquatic connectivity in tributaries of the West Fork of the Bitterroot River. Rehabilitate 

detrimental soil disturbance in historic timber harvest and terrace units. 
See LWF DEIS Abstract. I have very serious concerns, however, that neither the 

preferred alternative nor either of the other alternatives fully analyzed in the DEIS will 

achieve these stated goals. 

 As discussed below, I have provided comments and a sivlicultural prescription which 

will achieve the desired results. Accordingly, I request that the FS analyze my 

silvicutural prescription as a separate, proposed alternative or, failing that, the FS 

incorporate my harvest prescription and as many of my comments as possible into the 

alternative that is ultimately selected by the FS. 

 I believe that my more than four decades of experience performing forest 

management in western Montana provide me with the practical experience necessary to 

provide these comments. Specifically, I am a practicing forester, having received my 

forestry degree from the University of Montana, School of Forestry in 1971. Since that 

time I have worked full time in forest management on both public and private lands in 

western Montana, including successfully completing many projects in similar areas. 

Additionally, I have been involved in literally hundreds of meetings with the FS in 

Montana in an effort to help craft better projects. Moreover, I have designed and carried 

out other jobs on private lands in western Montana that have actually achieved the FS 

stated goal for the LWF of creating open stands of large tree species with fuel loads that 

would be less likely to transition fire into the canopy and be carried by crowns. The 

following comments are based on my experience in conjunction with leading forest 

scientists of the day. 

 

 Comments: 

 As stated in the DEIS 1.3 “Purpose” to effectively obtain the desired conditions the 

USFS will need to prioritize all mitigation factors in a descending order of importance. 

Some mitigation factors, however, cannot be implemented and therefore will not achieve 

the Purpose as stated. In order to correct this serious deficiency in the DEIS, I suggest 

that the USFS apply the following silvicultural prescription: 

 Reduce the BAF to 40-80 (10 foot between crowns absolute minimum crown closure) 

in a varied mosaic including the removal of large and small tress favoring retention of the 

larger, healthy trees. All treatment methods that meet the Purpose and Need and that can 

be safely operated, as is normal industry practice, shall be allowed (see Mimicking 

Nature’s Fire by Arno and Fielder). Ground based systems should be preferred. Care 

shall be taken to remove as many of the limbs and needles as possible to reduce the fuel 

loading. Areas may be clumped, thereby creating openings that break the fuel continuity. 

Specifically, large PP that have overlapping canopies may be retained in groups with no 

skidding under those crowns. Openings shall be created next to such clumps to average 

the BAF for the area. 

 All trees with two or more bug hits shall be removed as biomass. All chimneys that 

adjoin the private must have at least two breaks in the fuel continuity. Snags shall be 
retained at a density of 1.5-3 per acre average or less. Alternate thickets of small trees 

shall be retained and removed as necessary to meet the BAF specifications while also 

providing habitat for smaller wildlife. Particular care should be used to avoid the corn 

field effect. 

 Fire shall be reintroduced into the area responsibly, and care shall be taken to avoid 

returning fire to the area in the manner used in the Frazer Draw Project. Specifically, 

care shall be taken to avoid impact or damage to retained trees during the reintroduction 

of fire. Additionally, no large brush piles or concentrations shall remain on the treatment 

area at the conclusion of the treatment. 

 All ground based off-road operators shall complete a soil moisture test on a daily 

basis or anytime varying soil moisture conditions exist. This test shall consist of digging 

a hole that locates the most available soil moisture in the area of proposed operation. 

From the moistest soil a ball shall be formed in the hand and a ribbon of soil shall be 

squeezed from it. Anytime an unsupported ribbon consistently exceeds 1 1/2 inches in 

length, all ground-based operations shall be suspended in the area of the test. Any time 

these conditions exist the contractor shall notify the sale administrator that the contractor 

has suspended the ground-based operation. 

 THE VEGETATIVE PRESCRIPTION SHALL ALSO BE APPLIED IN THE 

RIPARIAN AREAS. The most important areas proposed in the treatment area contain 

water and have been invaded by conifers, which must be removed to restore the natural 

function of the stream and its vegetation. Aspen restoration must be a priority as well as 

beaver reintroduction neither of which are emphasized in the DEIS. The USFS shall 

follow the Montana BMPs to accomplish this. 

 Finally, it is absolutely necessary to prescribe a method for checking the silvicultural 

prescription during and after the project to determine whether the objective has been 

met. Specific methods must be written into the final EIS to insure that the silvicultural 

prescription is met. 

Conclusion: The Draft LWF EIS Does Not Comply With The FS’s Duties 

Under the Environmental Law. 

 In light of the environmental impacts of the considerable magnitude at issue here, the 

draft EIS issued by the FS does not comply with the requirements of NEPA. That is, 

NEPA requires the agency, among other things, to “study, develop, and describe 

appropriate alternatives to recommended courses of action in any proposal which 

involves unresolved conflicts concerning alternate uses of available resources.” 42 U.S.C. 

§ 4332(E). Here, however, the FS has only fully addressed two alternatives to taking no 

action and, of course, one of those is the alternative preferred by the agency. More 

importantly, there is not a meaningful difference between the two alternatives that were 

analyzed with respect to the key issues I have set forth above in my comments. In light 
of my comments, it is impossible to conclude that there existed just two reasonable 

alternatives to taking no action in this case. By failing to fully assess a range of 

reasonable alternatives, the FS has avoided its obligations under NEPA to take a hard 

look at the environmental consequences of its actions -- this is not appropriate. 

 Moreover, as set forth in my comments above, I have provided an alternative which 

allow the FS to fully meet its stated objectives for the project, to fully comply with its 

obligations under the Healthy Forest Restoration Act, National Forest Management Act 

and the Forest Plan for the Bitterroot National Forest, including but not limited to the FS 

obligation to manage for multiple use and to provide habitat for the full range of 

management indicator species (MIS) and threatened and endangered species. 

 The silvicultural methods set forth in my comments are the result of decades of on the 

ground experience in the relevant environment of western Montana forests and were 

prepared in consultation with some of the most preeminent forest scientists of the day. 

To the extent the FS rejects the use of any of the methods proposed in my comments it 

must be on the basis of clearly reasoned, publicly available analysis, and not the product 

of arbitrary and capricious agency action. 

 In conclusion, I reiterate my request that the Forest Service analyze at least one 

additional alternative containing all of the comments I have set forth above. Failing that, 

I urge the Forest Service to incorporate as many of my comments as possible into the 

alternative that is ultimately selected so that the alternative complies with the FS 

obligations under the law and fully explain why any comment that was not included has 

been rejected by the FS. 

 Finally, I note that after attending hundreds of FS meetings and helping provide 

alternatives to the FS on past projects, I have found little of the public’s input in any 

completed project. I sincerely hope this project will be different. It often appears that the 

FS uses the public comment to get through the process and then discards this input to 

simply do as the specialists please. See “Regurgitations of a Montana Woodsman”. This 

was very apparent in the recent Frazer Draw Project, which was a failure regarding public 

comment and implementation. 

 Thank you again for the opportunity to provide comments on this important project. 

 __________________________ 

Craig E. Thomas 

Forester 

Stevensville, Montana 59870 

406-363-8742 ckyber@bigsky.net
Forest Resources 

May 22, 2009 

Lower West Fork – Comments 

Forest Supervisor’s Office 

Bitterroot National Forest 

Hamilton, MT 59840-3114 RE: Lower West Fork Project 

To Whom It May Concern: 

On behalf of Smurfit-Stone Container Corporation, I wish to thank you for the 

opportunity to comment on the proposal to address the forest health issues on the 

Bitterroot NF within the Wildland Urban Interface along the Lower West Fork River 

drainage. Your proposal to address fuel loading, stand health and composition and the 

other issues within this landscape are worthy ones. It is good to see the Forest take a 

proactive stance in addressing these needs before catastrophic events such as fire and 

insect out breaks occur. With that in mind, I offer the following comments. 

Projects such as these are vital in numerous ways. First, it addresses the real threat of 

wildland fires. The Bitterroot well knows what the devastating effects of wild fires can 

cause on both resources and humans. Our forests have become increasingly 

overcrowded with ladder fuels that make fire suppression an increasingly difficult task. 

Second, it will improve forest health by removing suppressed and diseased trees. Even 

without considering wildfire risks, no one wants to see thousands and thousands of 

acres of beetle and diseased killed trees. The FS has as a mandate to manage these 

lands and the activities proposed does just that. 

Thirdly, and very important to me, is the economic benefits. Not only will this project 

employee people in removing the overcrowded trees, it also provides needed material 

for our paper mill. Smurfit-Stone can utilize these small trees as we can chip them up to 

use in our paper-making process. Additionally, there is the opportunity to grind the left 

over slash which can be burned in our boiler creating steam and electricity for our use. 

This helps in removing potential fuel from off the forests as well burning clean bio-fuel. 

In these tough economic times, it is important to provide material close to our mill which 

this project does. I also would state that, from an economic standpoint, the amount of 

skyline logging may make this project borderline to a purchaser. I understand these can 

of systems will need to be put in play do to the ground conditions. However, current 

market conditions make it difficult to add cost. I would recommend including more 

ground based areas to help offset the higher cost skyline units. 

Other benefits from this project include improving transportation systems by addressing 

BMP’s on existing roads and eliminating unnecessary roads. It will also improve wildlife 

habitat and water quality. 

P.O. Box 929, Frenchtown, MT 59834 406-626-5293 Fax 406-626-5839 
P.O. Box 929, Frenchtown, MT 59834 406-626-5293 Fax 406-626-5839 

Again, I thank you for the chance to offer my comments to you on the Lower West Fork 

Project. I recommend that this project be moved forward. If I can be of any assistance in 

terms of what Smurfit-Stone can offer to you, than please contact me. My phone 

number is 406-626-5295 (office) or 406-531-1693 (cell). 

Sincerely, 

Jim Mountjoy 

Area Manager 

Smurfit-Stone Container 

P.O. Box 929 

Frenchtown, MT 59834 

jmountjoy@smurfit.com

406-626-5295 

 
Friends of the Bitterroot 

PO Box 442 

Hamilton, Montana 59840 

WildWest Institute 

PO Box 7998 

Missoula, MT 59807 

Lower West Fork – Comments 

Forest Supervisor’s Office 

Bitterroot National Forest 

1801 N. First 

Hamilton, MT 59840-3114 

comments-southern-bitterroot@fs.fed.us

May 25, 2009 

Re: Comments on the Lower West Fork DEIS 

Dear West Fork Ranger Dave Campbell, 

The following comments on the Lower West Fork Draft Environmental Statement (LWF 

DEIS) are submitted by Friends of the Bitterroot and Wildwest Institute. 

As conservationists we advocate for nature and its many facets. One of its more awesome 

facets is the ability to heal itself. We note that nature, if allowed to work its wonders, 

could accomplish all of the listed purposes and needs of this project, and at no taxpayer 

expense. That would be a truly conservative alternative. Alternative 1 (no action), with 

the addition of restoration activities that would remove manmade impediments to natural 

recovery, could approximate this approach. The road restoration and culvert work 

described in Alternative 3 addresses that issue better than that in Alternative 2. 

Vegetation management in Alternative 3 is quite similar to Alternative 2. Knowing that 

you do not propose this project with the intent of no action, we will address our 

comments to Alternative 2, the proposed action, and, largely they will be relevant to 

Alternative 3. 

We fully support the proposed watershed restoration activities and believe much more is 

required in many areas to allow future logging to occur within legal limitations. 

We disagree with the rationale for the supposed need to remove fuel beyond the Home 

Ignition Zone (HIZ) or Community Protection Zone (CPZ) for the purpose of 

protecting human safety or private property. Cohen and Butler (2005) made 

recommendations regarding fuel treatment in an interface zone in the Boulder River 

canyon on the Gallatin NF. Based upon research, and investigation following instances 

of wildland fire, they specify the need to focus primarily on the HIZ, stating: “(W)e 

cannot mitigate a highly vulnerable HIZ with fuel reduction activities beyond the HIZ; 

a highly vulnerable HIZ remains highly vulnerable even when surrounded by a fuel 
break. ...The high intensity wildfire has no direct flame effect on the building ignition 

potential outside the HIZ.” 

Site-specific Forest Plan Amendments 

It appears that this project requires an amendment for each of four Forest Plan Standards. 

It has become routine to amend the Forest Plan for these standards on recent BNF timber 

sale proposals. Since revising the entire Forest Plan is long overdue and has proven to be 

problematic, perhaps NEPA analysis should be given to forest-wide amendments to the 

Forest Plan regarding these standards. That analysis would provide a larger scale, more 

comprehensive and updated assessment of the various situations not available with the 

piecemeal approach now being used. Important, difficult to repair or replace resources 

and values are at stake. 

The BNF Forest Plan Snags retention standard requires retention of all large snags, not 

just the gerrymandered formula proposed in its stead. Large snags are one of the most 

difficult vegetation components of the forest to replace. Only a lucky tree gets large and 

most large trees end their lives on the ground by way of wind, fire or chainsaw. We 

would like to see protection of all large standing snags. 

The amendment proposed for Winter Range Thermal Cover standard reads, “Existing 

thermal cover will be maintained within the Lower West Fork treatment units to the 

extent it does not conflict with meeting the project’s objectives.” Now, that is a 

manager’s dream “standard”. It is totally elastic, designed, a priori, to fit any desired 

timber removal. As such, it appears to be arbitrary regarding protecting elk. Given that 

you use new information and conditions to justify Forest Plan amendments, this standard 

should be evaluated in light of protecting elk security from wolves. Because of wolf 

predation elk security is increasingly dependent on thick timber next to their open 

grazing slopes. 

The amendment proposed for Elk Habitat Effectiveness (EHE) standard reads, “Existing 

elk habitat effectiveness will be maintained or improved within the Lower West Fork 

analysis area.” (DEIS, p.1-12) Given that the EHE standard regarding road density 

(security from human hunters) is not being met and can not be met in parts of the project 

area according to DEIS p.1-12, it would seem especially important to allow for more 

security from wolves, by leaving “thermal cover” where it exists, especially near 

meadows, within the project area. The FEIS must disclose the recently available spring 

2009 elk count numbers, which show a significant decline from the 5,950 elk in 2008, 

which shows a significant decline from the 8,169 elk in 2005. As the LWF DEIS admits 

(p.3.8-21), “No management activity can replace hiding cover in the immediate future”. 

The amendment proposed for Course Woody Debris (CWD) is arbitrary insofar as the 

definition of CWD is arbitrary. Lumping all wood 3 inches and larger into one category, 

CWD, does not distinguish the huge differences in fire behavior, soil building, moisture 

retention and wildlife values between a 3 inch branch and a 30 inch log. Forest Service 

scientist James Brown confirmed this verbally in a video-taped public meeting in 2001. 

Generally this failure to make important size distinctions leads to accumulating damage 

from loss of the more ecologically important larger logs and boles. 
Prescribed fire 

We do not see much discussion about the ecological impacts of prescribed fire other than 

the possibility of killing non-target trees. The FEIS should include analysis and 

disclosure of potential impacts of prescribed burning, especially in spring, to ground 

nesting birds or animals and impacts on plants, especially rare or sensitive plants. Spring 

burning goes against the rhythm of fire season and fire cycles that have shaped the forests 

and associated components over many thousands of years. It stands to reason that there 

are unforeseen and unintended consequences. Monitoring needs to be done. Given the 

relative speed and ease of treating large areas by prescribed fire, the potential threat of 

widespread ecosystem damage occurring before adequate understanding of negative 

consequences is a distinct possibility. 

Road building 

So-called temporary roads are only temporarily used but the damage to soils, weeds, 

watershed and wildlife can last a long time. They should not be considered simply 

erased off the land as easily as they can be erased off a map or a spreadsheet. Even 

after rehabilitation, the residual impacts of roads need to be recognized. Proposed 

‘temporary’ roads need to be shown on a map in the FEIS. 

Soils 

It bears reminding because it is so often forgotten; soils are the foundation of all life on 

dry land. 

NFMA requires the Forest Service to “ensure that timber will be harvested from 

National Forest System lands only where—soil, slope, or other watershed conditions 

will not be irreversibly damaged.” [16 U.S.C. 1604 (g)(3)(E).] Clearly the term 

“irreversible damage” is intended to be judged on a human time scale, not the 

geological time scale wherein even total loss of soil, from glacial scouring for 

example, can be reversed. The 60 plus years of lasting detrimental soil damage, 

compaction from logging, on the Bitterroot National Forest (BNF) would seem to fit 

the term ‘irreversible’ on a human time scale. 

Rather than assure adherence to NFMA by directly measuring and regulating loss of 

productivity of soils, the USFS uses the surrogate measurement of Detrimental Soil 

Disturbance (DSD). The accuracy of the supposed linkage of this substitution has not 

been adequately evaluated or disclosed. 

Region 1 of the USFS developed a soil quality standard (SQS) whereby only soil 

damage over a certain intensity/degree threshold qualifies as Detrimental. Thus much 

measurable soil damage does not even show up on the radar. 

The R1 SQS reads: 

“Design new activities that do not create detrimental soil conditions on 

more than 15 percent of an activity area. In areas where less than 15 percent 

detrimental soil conditions exist from prior activities, the cumulative 
detrimental effect of the current activity following project implementation 

and restoration must not exceed 15 percent. In areas where more than 15 

percent detrimental soil conditions exist from prior activities, the cumulative 

detrimental effects from project implementation and restoration should not 

exceed the conditions prior to the planned activity and should move toward 

a net improvement in soil quality.” 

That standard is totally inadequate; it throws the gate wide open. No amount of existing, 

logging-legacy, soil damage would preclude reentry for more logging. And the mitigation 

offered by the supposedly limiting clause, “should move toward a net improvement in 

soil quality”, will be provided by nature as soon as the heavy machinery leaves. The 

mechanical de-compaction proposed for restoration is experimental, with little known 

efficiency coefficients and may not go as deep as some existing compaction, thereby 

potentially masking compaction in the root zone. The heavy de-compaction machinery 

itself causes compaction and other types of soil damage. 

To our knowledge, the R-1 SQS has never received public review and comment nor has it 

been peer reviewed. It seems to have been simply adopted by fiat. Please disclose 

substantiation by scientific reports. 

The effectiveness of R-1 SQS needs validation monitoring to see if it leads to protecting 

soil conditions that truly satisfy NFMA requirements. 

The 15% soil quality standard simply measures aerial extent and does not incorporate the 

degree of detrimental soil damage beyond the thresholds of the definition of 

‘detrimental’. For example, in order to qualify as detrimental, compaction must exceed 

15% increase of bulk density (a measure of degree, coincidentally the same percent as the 

SQS number, an aerial measure). The amount of increase in any degree beyond that is 

routinely not disclosed, nor is the depth of compaction disclosed. This information is 

necessary to determine the actual extent of damage and the degree of irreversibility. The 

information would also be necessary to design adequate mitigation and amelioration 

implementation. 

Discovery that an activity area has 15% or more detrimental soil damage should 

disqualify the area from further ground disturbing activities. The still experimental soil 

compaction amelioration techniques proposed are only partially effective and may in fact 

add to soil damage by way of mixing mineral soil into top soil, aerating soil organic 

matter (and thereby ‘burning’ it up more quickly), spreading weeds, fragmenting 

mychorizae or otherwise disrupting the soil community. 

It is admitted in the DEIS, p.3.5-16, that the proposed soil amelioration technique “does 

not immediately restore soils to pre-disturbance levels”. 

As discussed and disclosed in the DEIS, the anticipated increase in DSD due to proposed 

activities is significantly lower than the best available science indicates. There is 

available agency science quite specific to the conditions here in the Bitterroot. This 

underestimation in the LWF DEIS runs counter to the best available agency science of 

expectable DSD. It risks exceeding R1 SQS in certain units. 
Ken McBride, former BNF soils scientist with long professional experience on the BNF 

states, “Over the past 14 years monitoring of summer, ground-based logging effects on 

soils conducted on the Bitterroot National Forest by the Forest Soil Scientist has shown 

that 75% of the units failed to meet R-1 SQS. Over this period of monitoring the average 

detrimental soil damage from ground-based summer logging was 30%.” (2005, MEF 

DEIS p.3.5-20) 

This contrasts significantly with the 10% DSD factor used (LWF DEIS, p.3.5-15) to 

project new DSD from ground based skidding. Similarly the LWF DEIS, (p.3.5-17) uses 

indefensibly low estimates, 8% increased DSD, due to skyline skidding. This does not 

agree with the best BNF specific, long-term DSD monitoring reported in 2005 (MEF 

DEIS) by McBride. 

The LWF DEIS (p.2-10) states, “Units 1, 3, and 12 have levels of detrimental disturbance 

from historic logging that are near or exceed the Region 1 Soil Quality standards.” Use of 

experimental soil de-compaction machinery is proposed to ameliorate soil damage in 

Unit 3 (with 34% DSD), parts of Unit 1 (19% DSD) and Unit 12. No depths of existing 

compaction are disclosed nor are areas and depths of proposed mechanical amelioration 

disclosed in the DEIS. No accounting of net soil conditions expected after the timber sale 

include any efficiency factors for the proposed de-compaction devices. If it is only 30% 

efficient then 3 times as much area would need to be treated to come out equal, and that 

discounts entirely the additional damage of various types caused by the de-compaction 

machinery. Where will deep compaction remain after the project? It is impossible for the 

public or the Decider to tell if R1 SQS will be met. 

The net effectiveness of mechanical de-compaction soil amelioration techniques needs to 

be analyzed and disclosed, as well as the degree of above mentioned ancillary impacts to 

the soil, (mixing mineral soil into top soil, aerating soil organic matter and thereby 

‘burning’ it up more quickly, spreading weeds, fragmenting mychorizae or otherwise 

disrupting the soil community). These effectiveness factors would be necessary to 

determine the net benefit to the soil resource after project amelioration activities are 

implemented. McBride reports,”It is acknowledged that the effectiveness of soil 

restoration treatments may be low, often less than 50 percent.” (MEF DEIS p.3.5-20) He 

used a 30% effectiveness factor, using compaction as the only yardstick. 

It appears the LWF DEIS fails to disclose analysis of DSD caused by burning slash 

piles. The MEF DEIS (p.3.5-25) reports that about 2% DSD can be expected from this 

cause. This damage can not be ameliorated immediately and so would add to the DSD 

caused by the project and remaining after implementation. This factor must be 

included in LWF EIS soils analysis. Mitigation proposed to reduce DSD and prevent 

spread of noxious weeds states, “The entire duff profile should be moist to the touch in 

the pile locations.” (LWF DEIS, p.2-16) Unless this condition is met directly under the 

piles it may be meaningless because the piles intercept precipitation potentially leaving 

the ground under them drier than ground at that location not under the piles. 
As requested in our scoping comments, total acreage of road surface, including 

temporary, in each activity area should be displayed alongside the detrimental soils 

condition information. 

Soil conditions, including roads and areas with detrimental soil damage, should be 

mapped and disclosed on a sub-watershed basis within the project area in order to 

assess cumulative impacts. This is important in the disclosure of cumulative watershed 

impacts because detrimental soil compaction would add to impacts from road 

compaction, ECAs and hydrophobic soils (DEIS, p.3.5-7) in increased and flashier 

water runoff, which causes higher high flows, lower low flows, and bank instability. 

(See esp. Lavene Creek section below) 

The DEIS discusses (p.3.5-9) Soil Erosion and Mass Movements, “In summary, if 

future fires are within the historic range of variability, long-term effects of erosion and 

mass movement are likely to be relatively small. Fire severity exceeding the historic 

range of variability could have detrimental effects on erosion and mass movement...” 

This discussion is used to rationalize logging in order to avoid “fire severity exceeding 

the historic range of variability”, and thereby save the soils. We appreciate not reading 

in this EIS about “catastrophic” forest fire, but high severity fire “exceeding historic 

range” seems to be overplayed for dramatic effect. 

In fact almost every debris flow on the BNF after the 2000 fires spread its fan of 

alluvium as a thin layer on top of an existing much deeper, bajada-like, fan at the break 

in slope below the blowout. These ancient debris flow relics tell us that the 2000 fires 

were not outside the range of historic variability. There have been many such events 

over thousands of years. These land forms silently disagree with your rationale for 

logging to save the soil from dreaded “highly severe” forest fire “outside the historic 

range of variability”. Even after the 2000 debris torrents tried to shout out about this 

recurrent, natural phenomenon, these debris fans are still magnets for new homes. 

Soils – Unit 1

Unit 1 has existing DSD on 19% of the unit. Even with the proposed mitigation of ground 

skidding only in winter conditions, an increase in soil compaction is inevitable. Ken 

McBride reports, “monitoring...over the past 14 years has shown that 58% of the groundbased winter logged units failed to meet R-1 SQS. Winter logging resulted in an average 

of 16% detrimentally damaged soil. This observation means winter logging mitigations 

have been unexpectedly ineffective. Newer, more stringent requirements may also be 

unexpectedly ineffective and should not be relied upon in areas already over SQS 

“limits”. (MEF DEIS, p.3.5-21) 

Additionally, “soils in unit 1 are not conducive to subsoiling treatments because the 

coarse fragment content is high.” (LWF DEIS, p.2-10). And so the proposed 

“amelioration” technique is, “Higher levels of woody debris will enhance the 

development of organic soil horizons, microbial populations, and other soil functions 

essential to restoring pre-disturbance conditions.” It is not clear in the DEIS if only the 

55 acres of winter ground skidding or all of Unit 1 would receive the slash blanket 

treatment. 
The DEIS does not appear to disclose the additional DSD attributable to the new 

“temporary” road planned for Unit 1 nor does it appear to disclose the additional 2% 

DSD expectable from burning slash piles (MEF DEIS, p. 3.5-25) 

Because of the many undisclosed factors (unspecified amelioration techniques, lack of 

amelioration effectiveness coefficients, unaccounted temporary road and slash burning 

DSD), it is impossible for the Decider or public to intelligently anticipate the soil 

conditions in Unit 1 upon implementation. 

Thus, Unit 1, with 19% existing DSD would receive additional (even more than the DEIS 

reports) DSD from proposed logging, new roads and slash pile burning followed by only 

the cursory rehabilitation of leaving slash, which admittedly “does not immediately 

restore soils to pre-disturbance levels”. 

This does not satisfy R1SQS requirement that “the cumulative detrimental effects from 

project implementation and restoration should not exceed the conditions prior to the 

planned activity”. 

If the BNF assertion that this proposed activity in unit 1 fits within the R1 SQS is 

allowed to stand, it clearly shows that the R1 SQS is arbitrary and capricious and is not 

sufficient to protect soils per the NFMA mandate. 

The legitimacy of the R1 SQS needs to be challenged in specific cases. Unit 1 is a good 

example. 

Watersheds 

As requested in our scoping comments please disclose on maps and discuss all site 

specific watershed work, road restoration and road use restrictions that were planned 

under previous NEPA decisions within the proposed project area. What activities or road 

use restrictions were implemented and what activities or road use restrictions were not? 

We have seen numerous NEPA projects where planned restoration work was never done. 

In cases where the planned restoration was required to bring the project area into 

compliance with Forest Plan standards, the result has been that projects outside legal 

limits defined by Forest Plan standards have been implemented in anticipation of 

restoration benefits that never arrived. The negative social effects of loss of public trust 

and increasingly on betrayed local job expectations are accumulating. The information 

requested would be an indicator measurement. It will give the public and decision maker 

tools to help measure the likelihood that various aspects of the project will actually get 

done within the “Temporal Scope” described as 10 years at DEIS p.1-13. FOB would 

like to see that “assumption” of 10 years for project implementation rationalized in the 

FEIS with the easily available administrative paper work research information we have 

requested. 

The LWF DEIS states on p. 2-7, “Almost 19 miles of road would be stored and another 

10 miles would be decommissioned. Twenty-two culverts would be removed at roadstream crossings, 16 of which deliver sediment to streams and two that block fish 
passage... “(emphasis added). Note the DEIS does not say could be. We assume that 

work would be done within the ‘temporal scope” of ten years if the project is 

implemented. 

The LWF FEIS should disclose which restoration activities are needed to bring the 

project into compliance with applicable standards and laws and which restoration 

activities are magnanimously meant to improve the situation over and above legally 

defined limits in the project area. The former should be mandatory; the latter might be 

optional. 

The routine failure by the BNF to deliver on what are publicly perceived to be NEPA 

Decision restoration commitments has become quite controversial. Some results of this 

apparent nonfeasance are: loss of public trust, accumulating watershed damage, 

depression of future logging opportunities (limited by excessive and un-restored damage, 

especially where TMDLs are in place), along with the obvious loss of restoration jobs. 

The DEIS discloses, “Soil disturbance is an unavoidable consequence of forest 

management activities.” (p.3.5-8) Other damage to watersheds and wildlife would also 

unavoidably result from commercial logging. Given that additional certain damage, FOB 

wants solid, dependable assurance in the FEIS and Record of Decision that the 

restoration work described in the LWF project will be done in a timely manner if the 

commercial logging is done. Stewardship contracts may offer one possible avenue. 

However it gets done, allocation of money and political attention are routinely strongly 

influenced by the Forest Service’s chosen priorities. 

Table 3.6-2 on DEIS p.3.6-8 should include a column disclosing the expected increase in 

sediment delivery to each stream from log hauling. 

Watershed function is affected by water quality and water yield. The West Fork is listed 

as impaired (MT 303d) water quality primarily due to sediment. Temperature is also an 

important quality of water; colder is better for the resident fish. Roads are the primary 

source of sediment in streams, both from runoff as well as dust. Loss of riparian 

vegetation and over-widening channels causes warming streams. Equivalent clearcut area 

(ECA) is a metric used to determine the probability of a harvest-related water yield 

increase. (LWF DEIS, p. 3.6-5) Sediment and water yield are interrelated in their effects 

and can behave in a synergistic fashion on the stability of stream channels/stream banks. 

The effect of increased water yield due to harvest can be multiplied by the increase in 

sediment due to log haul. 

Critical information necessary to estimate impacts of project activities on water yield, 

sediment delivery and their cumulative effect on channel stability is missing from the 

LWF DEIS. Water yield and sediment delivery are both affected by soil conditions in 

addition (or multiplication?) to the ECA measurement. Sub-basin Detrimental Soil 

Damage maps, and analysis need to be made available to know where potential for 

cumulative problems with areas of high ECAs, burned/hydrophobic soils, high road 

densities (open and closed) and otherwise compacted soils. 
These are all significant factors contributing to the behavior of water runoff. The effects 

can be flashier yield – higher high flows and lower availability of late season water 

flows. 

Watershed - Lavene Creek 

Lavene Creek has an ECA listed as 27%. (LWF DEIS, p.3.6-11). Proposed logging 

would increase ECA to 28% (DEIS, p.3.6-27). This exceeds the 20 – 25% ECA 

threshold of channel stability. Unit 3 appears to be within the Lavene Creek watershed. 

It has 55 acres of DSD compaction, 34% of the unit, and is slated for 98 acres of 

summer ground skidding and 65 acres of skyline. According to the best available DSD 

history on the BNF (see McBride ref above) about 30% DSD on the 98 acres of 

summer ground skidding can be expected. That would add about 30 acres to the 

existing 55 acres, bringing the total DSD to about 49%. With the additional 8% DSD 

expectable from skyline logging (LWF DEIS, p.3.5-17) of 65 acres, over 50% of the 

unit would suffer DSD. This excessive soil compaction will add to the increased 

volume and flashier runoff attributable to the, already over threshold, 27% ECA. Log 

hauling over the 6 stream crossings will contribute an undisclosed amount of additional 

sediment over and above the usual 10.2 tons per year sediment entering Lavene Creek 

from those 6 stream crossings. The haul road, NFR 5630, follows within 300 feet of 

fish bearing Lavene Creek for 0.4 miles (DEIS, p. 3.7-14) Road 5630 will have 404 log 

truck trips (one-way or round?) (DEIS, p.3.7-15) How much additional sediment from 

dust and runoff at crossings is expected from hauling unit 4? The potential for adding 

sediment to the impaired, 303d listed West Fork is minimized on DEIS p.3.6-13, where 

it says, “but water does not flow into the West Fork at all flow levels” (emphasis 

added). Of course it is the higher flow levels that are the issue, when it presumably 

does reach the West Fork. Channel instability in Lavene Creek as well as sediment fro 

dust and runoff could carry sediment into the West Fork at high water events in Lavene 

Creek. Additional sediment would violate the TMDL prescription for the West Fork 

and thereby violate the Clean Water Act. Some critical factors are missing in this 

thinly sliced risky calculus. 

Fisher

FOB is currently a co-petitioner to the USFWS for listing of the Northern Rockies fisher 

as a threatened species. The Northern Rockies fisher has been shown to be a genetically 

distinct population that is not well connected to other fisher populations, and is therefore 

more precarious than even their low numbers suggest. They require large snags and dense 

forest. The Bitterroot NF along with the Idaho forests to the west is the stronghold of 

these rare animals. Alternative 2 treats about 3,200 acres of potential and suitable marten 

and fisher habitat, about 18% of suitable habitat in the project area. (DEIS, p2-25). This 

seems like a lot to take away from the fisher, when they are having such a hard time. 

Additionally, after thinning the accessibility to snowmobiles will increase, further 

diminishing fisher habitat effectiveness. This impact needs to be disclosed in the FEIS 

and mitigation via area closures analyzed. 

Recreation 
LWF DEIS p.3.12-2 under Travel Management Direction, claims, “The Bitterroot 

National Forest Visitor Map (2005) displays motorized travel management restrictions 

established under current federal laws and regulations on National Forests.” In fact this is 

not entirely true. The 2005 map made changes to road designations without proper 

environmental analysis, and therefore illustrates many roads as open to vehicles up to 50” 

in width where those vehicles were in fact prohibited by previous NEPA decisions. The 

2005 BNF Visitor and Travel Map appears to incorporate a spreadsheet released by the 

BNF titled, “Roads Open to OHV’s and Closed Yearlong to Full size Vehicles.” This 

spreadsheet lists roads with map codes R-4, R-6, R-7, and 90. According to the BNF 

Visitor and Travel Map, these codes mean: 

• R4 – “Reduce soil erosion or protect wildlife, and provide wildlife security 

during hunting season.” 

• R6 – “Reduce soil erosion” 

• R7 – “Protect wildlife and provide wildlife security during hunting season.” 

• Code “90” roads are not defined and are part of the forest’s internal coding. 

It is apparent that the BNF did not comply with NEPA requirements when it updated its 

Visitor and Travel Map in 2005, as it changed the protections established in prior 

decision documents that ensured compliance with NEPA, NFMA, and other 

environmental mandates. Many miles of roads in the project area that were closed 

yearlong, in prevailing original NEPA documents, to motorized use for the purpose of 

protecting wildlife and wildlife security or for preventing erosion, have been opened 

seasonally to ATV, motorbike and/or snowmobile use by the Travel Map, see especially 

Road Restrictions # 4 and #6 in this project area. These changes were done by fiat with 

no NEPA analysis or public process and no science to show any differences in impacts 

between full-sized vehicles and smaller motorized vehicles. regarding the resources in 

question. Where is the science? This is not a question of dueling science; we do not know 

of any supporting science. Rather, there is a growing body of scientific literature that 

demonstrates ORV impacts to a variety of forest resources, very similar to that of full 

sized vehicles. 

In your discussion of Travel Management Direction you should identify the authority and 

make available in the LWF FEIS documentation of the decision to open code “90”, R-4, 

R-6 or R-7 roads to ORVs. 

Roads coded “90”, R-4, R-6 or R-7 were designated and maintained at maintenance level 

1 (ML 1). In regards to this maintenance level, the Forest Service Transportation System 

Maintenance Handbook 7709.58 Chapter 12.3(2)(a) states: 

“Level 1. Assigned to intermittent service roads during the time they are 

closed to vehicular traffic. The closure period must exceed 1 year. Basic 

custodial maintenance is performed to keep damage to adjacent resources to 

an acceptable level and to perpetuate the road to facilitate future management 

activities. Emphasis is normally given to maintaining drainage facilities and 

runoff patterns. Planned road deterioration may occur at this level. 

Appropriate traffic management strategies are ‘prohibit’ and ‘eliminate.’ 

Roads receiving level 1 maintenance may be of any type, class, or 

construction standard, and may be managed at any other maintenance level 
during the time they are open for traffic. However, while being maintained at 

level 1, they are closed to vehicular traffic, but may be open and suitable for 

nonmotorized uses.” 

The BNF appears to have opened up a large amount of ML 1 roads to ORV use without 

NEPA and without changing the maintenance level designations. In doing so, the BNF 

created an existing system that is in violation of NEPA and Forest Service Directives. In 

order to have an existing system in line with current the Forest Service handbook, the 

BNF should list all ML 1 roads as closed to vehicular traffic. 

This situation must be disclosed and discussed within the LWF FEIS. How many miles of 

R-4, R-6, R-7, code 90 roads fall within the LWF project area? What were the purposes 

of original NEPA closures? What are the names of the original NEPA documents that 

authorized the original yearlong closures? 

 

 All modeling of watershed, wildlife and soils impacts applied to the LWF EIS should 

reflect the reality that the R-4, R-6, R-7, code 90 roads are not closed yearlong. 

Specifically we ask that you disclose if these roads have factored into the LWF EIS 

resource impact analyses just as they would if they were open seasonally to full size 

vehicles. If not, why not. In order to account for cumulative impacts to the resources 

involved this situation must be disclosed and discussed in the FEIS. 

For example, Piquett Creek does not meet EHE standards (DEIS p3.8-16) and 

purportedly can not, without closing access roads to trailheads. There is a very high road 

density of R-4 and R-6 roads in this area. How does the opening of these roads impact the 

watershed problems that caused their former closure after NEPA analysis and 

authorization? How does their opening affect wildlife security regarding hunting, calving 

and winter forage? 

Reference to specific original NEPA documents needs to be part of disclosure. The 

original purpose of such closures needs to be disclosed and discussed, if it is within the 

project area. 

Allowing ORVs to go around locked gates directly causes damage by forcing vehicles off 

the road prism. It also trains-in and sends a clear message that reinforces the already 

prevalent notion that it’s OK to drive off road and around locked gates. 

The FEIS must disclose any impacts to fisher from increased snowmobile use due to 

improved accessibility after thinning. Mitigation by area closures should be part of the 

project. 

Roadless/Unroaded 

 Any categorical distinction between roadless land and unroaded land is divorced from 

the land itself. It is simply administrative, certainly not ecosystem oriented. Our concern 

is for the biological value of the land and water. 
Another false distinction arises where DEIS P.3.12-9 states, “...there are areas totaling 

approximately 9,995 acres, which some members of the public have considered 

“unroaded” within the analysis area.” In our view these 9,995 acres either are or are not 

unroaded. Please identify those acres that actually are unroaded on the ground and use 

that for your analysis. It appears dismissive to say “considered” and to put “unroaded” in 

quotes in the DEIS. With your language and approach, you cloud important ecological 

considerations about the land by sowing doubt with allusions to the credibility of the 

messenger. Whatever acres of land are unroaded (no quotes) on the ground have the same 

potential values as any other roadless land. Sixteen years ago the Buck-Little Boulder 

EIS on the West Fork RD analyzed impacts to actual unroaded land (no quotes in 

original) and not just land “considered” unroaded by some third party. It appears that 

laudable Forest Service approach has changed. 

Some activities within IRAs and “Friends of the Bitterroot Unroaded” areas are shown on 

a map at DEIS p.3.12-5 and a Table 3.12-3 at DEIS p.3.12-13. Where is the 1.4 miles of 

“temporary” road that would be built in unroaded land, according to Table 3.12-3? It 

does not seem to be on the map. This information should be disclosed on a map in the 

FEIS. 

FOB strongly opposes road building in both unroaded and roadless areas 

No analysis or disclosure of impacts to the special regionally important biological 

corridor values of the Allan Mountain IRA are found on p.3.12-8. This area has been 

identified by FOB and American Wildlands as an important biological corridor. See the 

“West Fork Bitterroot” zone of “The Hub” map from American Wildlands’ Priority 

Linkage Assessment for the Hub Conservation Area, available at www.wildlands.org 

Allan Mountain IRA is part of a critical hub of linkages connecting the Salmon Selway 

ecosystem with the Sapphire Crest route to the Northern Continental Divide ecosystem as 

well as the route south along the Divide to the Yellowstone ecosystem. Failure to 

disclose impacts on biological corridor values in the DEIS is a serious flaw. 

We believe that road prisms make the most identifiable and manageable boundaries for 

roadless and unroaded areas. Areas without roads are then truly identified as roadless 

areas. That sensible approach stays true to the English language as well as the ecological 

values of areas without roads. 

According to p.3.12-9, stumps within areas without roads reduce the Apparent 

Naturalness of an area, thereby diminishing Wilderness Characteristics. This policy is 

misdirected, but given its use, we therefore oppose thinning in areas without roads 

identified on the FOB roadless/unroaded map. 

Submitted for Friends of the Bitterroot by, 

Jim Miller, president 

Submitted for WildWest Institute by, 
Matthew Koehler, Executive Director 





















Lower West Fork Project

Record of Decision

Bitterroot National Forest

West Fork Ranger District

Ravalli County, MT

July 2010

Responsible Agency: USDA Forest Service

Responsible Official: Julie K. King

Forest Supervisor

1801 No. First

Hamilton, MT 59840-3114

For Further Information Contact: David M. Campbell

West Fork District Ranger

6735 West Fork Road

Darby, MT 59829

(406) 821-1211

Project Area Location: T2N R21W Sections 27-36, T1N R20W 

Sections 6-8, 17-20, 29-32, T1N R21W 

Sections 1-30, 34-36, T1N R22W 

Sections 1, 12-15, 23-26, and T1S R21W 

Sections 1-4, 10-12, 14-16, 21, 22 PMM, 

Ravalli County, Montana. 
Record of Decision

Lower West Fork Project ROD - 3

TABLE OF CONTENTS

1.1 DECISION OVERVIEW ........................................................................................................................................5

2.1 BACKGROUND...................................................................................................................................................5

3.1 PURPOSE AND NEED .........................................................................................................................................7

4.1 DECISION...........................................................................................................................................................8

5.1 ALTERNATIVES CONSIDERED ...........................................................................................................................17

5.1.1 ALTERNATIVE 1..............................................................................................................................................17

5.1.2 ALTERNATIVE 2..............................................................................................................................................17

5.1.3 ALTERNATIVE 3..............................................................................................................................................18

5.2 ALTERNATIVES CONSIDERED BUT ELIMINATED (FEIS PP. 2-17) .......................................................................18

6.1 RATIONALE FOR MY DECISION.........................................................................................................................20

7.1 PUBLIC INVOLVEMENT .....................................................................................................................................25

8.1 FINDINGS RELATED TO OTHER LAWS AND REGULATIONS ...............................................................................26

9.1 APPEAL PROVISIONS ........................................................................................................................................30

10.1 IMPLEMENTATION ........................................................................................................................................31

11.1 FURTHER INFORMATION AND CONTACT PERSON..........................................................................................31

LIST OF REFERENCES CITED IN THIS DECISION.........................................................................................................32

TABLE 1: UNIT TREATMENTS UNDER ALTERNATIVE 3-MODIFIED.............................................................................9

TABLE 2: STORED OR DECOMMISSIONED ROADS UNDER ALTERNATIVE 3-MODIFIED............................................15

TABLE 3: MANDATORY STEWARDSHIP ROAD TREATMENTS UNDER ALTERNATIVE 3-MODIFIED............................16

TABLE 4: SUMMARY OF ACTIVITIES FOR ALTERNATIVE 3-MODIFIED......................................................................16

TABLE 5: COMPARISON OF ACTIVITIES BY ALTERNATIVE ........................................................................................17

TABLE 6: COMPARISON OF MEASURES TO MEET THE PURPOSE AND NEED OF THE LOWER WEST FORK PROJECT..21

FIGURE 1: LOWER WEST FORK PROJECT AREA AND VICINITY MAP SHOWING THE WILDLAND URBAN INTERFACE 

BOUNDARY...............................................................................................................................................................4

FIGURE 2: LOWER WEST FORK PROJECT SELECTED ALTERNATIVE - TREATMENT AREAS ON THE WEST SIDE OF THE 

WEST FORK RIVER...................................................................................................................................................11

FIGURE 3: LOWER WEST FORK PROJECT SELECTED ALTERNATIVE - TREATMENT AREAS ON THE EAST SIDE OF THE 

WEST FORK RIVER...................................................................................................................................................13

APPENDIX A – MITIGATION MEASURES
Record of Decision 

ROD - 4 Lower West Fork Project

Figure 1: Lower West Fork Project Area and Vicinity Map showing the Wildland Urban Interface 

Boundary
Record of Decision

Lower West Fork Project ROD - 5

RECORD OF DECISION

LOWER WEST FORK PROJECT

USDA Forest Service

West Fork Ranger District, Bitterroot National Forest

Ravalli County, Montana

1.1 DECISION OVERVIEW

After thorough review of the Lower West Fork Project Final Environmental Impact Statement (FEIS) and 

public comments received throughout the analysis process, I have decided to modify and select Alternative

3. I modified Alternative 3 by adding the following features from Alternative 2: 

Ø commercially thin Unit 60 on the west side of the West Fork of the Bitterroot River (West Fork 

River)

Ø retain the option to treat potential noxious weed spread with herbicides 

Ø treat the prescribed fire units in the Wildland Urban Interface (WUI) on the east side of the West

Fork River 

Ø decommission National Forest System Road (NFSR) 13841 from its junction with NFSR 74327

and decommission NFSR 13424 from its junction with NFSR 13425

I believe my decision is the best balance between enhancing forest conditions and reducing the potentially

negative effects of forest management. My decision will reduce the risk of crown fire in the WUI, and 

stream sedimentation, and improve forest resiliency, fish population connectivity, and soil productivity.

The potentially negative effects of the activities required to achieve these objectives will be eliminated or 

reduced through project design and the application of Best Management Practices (BMPs). This Record of 

Decision (ROD) explains the rationale for my decision. 

The ROD is organized as follows:

Ø Background information about the proposal and the purpose and need for the project

Ø Description of the activities approved in the modified Alternative 3

Ø Criteria and rationale I considered in selecting this alternative

Ø Description of the public involvement process

Ø Consistency findings with applicable laws and policies

Ø Project implementation and contact information

This document and my decision are based on and reference the analysis in the Lower West Fork Project 

FEIS and Draft EIS (DEIS), and information in the project file. 

2.1 BACKGROUND 

The Lower West Fork analysis area is located about 15 air miles southwest of Darby, Montana (Fig. 1). 

National Forest System land makes up most of the analysis area though about 3,400 acres of private land 

exist along the West Fork River. The Selway-Bitterroot Wilderness borders the analysis area to the west 

and Shook Mountain and Medicine Point lookout mark the border to the east.

The goal of this project is to expand fire management options beyond suppression in the event of an 

ignition by decreasing stand density and fuel loads. The intent is to re-establish fire as a natural process at 

the intensities and frequencies that shaped this landscape. Managing fuel loads and stand density using 

timber harvest, non-commercial thinning, prescribed fire, and natural ignitions would reduce fire intensity 

at the Bitterroot National Forest boundary.

I have decided to treat this area because:
Record of Decision 

ROD - 6 Lower West Fork Project

Ø The Forest Plan directs the use of prescribed fire to maintain healthy, dynamic ecosystems that 

meet land management objectives and to emphasize fire ecology implications in its application 

(Forest Plan Appendix M).

Ø Management Area direction requires fire planning be designed to 

§ protect and enhance timber investments and values (Forest Plan pg. III-7)

§ protect and enhance winter range habitat (Forest Plan pg. III-13)

§ protect visual quality and minimize fire danger and insect and disease problems, and assure 

establishment and protection of stands (Forest Plan III-20, III-28, III-34, III-60)

§ perpetuate natural ecosystems (Forest Plan III-43)

Ø The Wildland Fire Risk Mitigation Plan identifies fuel reduction as a high priority (Community 

Wildfire Protection Plan; DNRC et al. 2006) (FEIS pg. 1-1).

§ Treating fuels in the WUI adjacent to the West Fork River moderates potential fire intensity 

adjacent to the private land boundary. Lower fire intensities will allow fire protection 

agencies more options to manage the fire, and protect the natural resources and private land 

developments. 

Ø The ponderosa pine/Douglas-fir forests are densely stocked, declining in resilience to 

environmental stressors, and shifting composition from ponderosa pine to Douglas-fir (FEIS 

pgs. 1-6, 3.2-8).

§ The trees left after thinning will be predominantly large ponderosa pine mixed with large 

Douglas-fir. These trees will have adequate growing space to restore their defense 

mechanisms and resist insect and disease infections. The larger trees also have thicker bark 

that is more resistant to fire. The spacing between trees will inhibit fire from transitioning 

to the crown and reduce the potential burning time adjacent to the tree bole. These 

conditions will improve tree survival in a fire. 

Ø High fuel loads and crown fire potential in the low elevation ponderosa pine/Douglas-fir forests 

limit fire management options (FEIS pgs.1-5, 3.3-11, 3.3-12).

§ Reducing fuels will allow more flexibility in the management of natural ignitions and

promote the natural role of fire in the ecosystem.

Ø The fuel treatments augment the area of fuels reduction created by the Frasier Interface project 

and the School Point Ecoburn and improve the management of fire behavior on the landscape 

scale.

Ø The project analysis area provides opportunities to evaluate soil, watershed, and fisheries 

projects that would reduce sedimentation in the West Fork River, which is listed as impaired 

(Montana Department of Environmental Quality (MDEQ 2008)) (FEIS pgs. 1-7, 3.5-6, 3.5-6, 

3.6-8, 3.6-9).

§ Storing and decommissioning roads no longer used for forest management, and 

rehabilitating disturbed soils will improve water infiltration to the soil and reduce runoff 

and sedimentation. Less sediment in the streams and more water stored in the soil will 

improve water quality and fish habitat. 

§ Removing fish barriers will improve the genetic mixing of fish populations and improve 

their resilience to environmental stressors. 

§ Rehabilitating soils in the terrace units and units with legacy soil compaction will augment 

the natural soil recovery process. 
Record of Decision

Lower West Fork Project ROD - 7

3.1 PURPOSE AND NEED

The purpose of the Lower West Fork project is to improve forest resilience to environmental stressors such 

as fire, insects, and disease and reduce fuel loads in and adjacent to the WUI. An additional purpose of this 

project is to reduce soil compaction on terrace units, and reduce sedimentation and fish barriers created by 

roads and road crossings.

The purpose of this project is not to prevent insects, disease, and fire from regulating forest conditions but 

to maintain forest conditions that support endemic populations and historic fire intervals and intensities. 

Forest conditions following treatments would be open stands of large, predominantly ponderosa pine trees 

with fuel loads appropriate to the site and fire interval. These stands would have less competitive stress and 

better resistance to insect and disease occurrences. The lighter fuel loads and wider spacing between trees 

would:

1. Reduce crown fire hazard in low elevation ponderosa pine/Douglas-fir forests

2. Improve forest resilience to natural disturbances, particularly the resilience of large diameter 

ponderosa pine trees 

3. Maintain or increase shade intolerant species, specifically ponderosa pine

Soil compaction would be reduced on terrace units, historic skid trails in Units 3 and 12, and in the portion 

of Unit 1 where detrimental soil disturbance exceeds Regional soil quality standards (FEIS pgs. 3.5-5). 

Sedimentation in tributaries to the West Fork River would be reduced by storing and decommissioning 

roads, and fish passage would be restored by replacing culverts that block fish migration. These projects 

would improve the overall soil, watershed, and fisheries conditions and enhance the biological resilience in 

the Lower West Fork analysis area. 

The differences between current conditions and desired conditions and the effect of those conditions on 

ecosystem processes determined the need for the proposed actions in Lower West Fork analysis area. 

Ø Forest vegetation has shifted from open stands of primarily large ponderosa pine to more 

uniform and dense stands of Douglas-fir, especially in the understory, in the Lower West Fork 

area. These dense stands are more prone to intense wildland fires and insect or disease 

epidemics (Graham et al. 2004; USDA 2004, FEIS pgs.1-6, 3.2-10 to 3.2-17, 3.3-6 to 3.3-12).

Ø Forests in the Lower West Fork analysis area have departed from historic fire frequency 

intervals causing changes in vegetation structures, fuel loads, and fire severity. This means that 

fires could burn at higher intensities than is typical for these types of forests. The potential loss 

of forest ecosystem and private property components is higher because of these conditions 

(FEIS pgs. 3.3-6 to 3.3-12).

Ø The forest around the Lower West Fork WUI is a high priority treatment area based on values at 

risk and potential fire behavior (FEIS pg. 3.3-6). The Lower West Fork project would reduce 

fuel loads and modify areas of high-intensity, crown fire behavior to low or moderate intensity 

surface fire behavior (FEIS pg. 3.3-12).

Ø The Bitterroot Community Wildfire Protection Plan recommends restoration of fire-adapted 

ecosystems by restoring healthy, diverse, and resilient ecological systems to minimize fire 

severity in the priority areas. 

Ø The Rombo Fire burned over 1,400 acres of old growth forest in the Lower West Fork analysis 

area, which reduced old growth habitat by 33 percent (FEIS pg. 3.8-4). Reducing fire intensity 

in the analysis area protects remaining old growth habitat. 

Ø Roads contribute sediment to tributaries of the West Fork River, which is listed as impaired by 

sediment (MDEQ 2005) (FEIS pg. 3.6-2). Reducing sediment by storing and decommissioning 

roads no longer used for forest management would decrease sediment in the West Fork River

and its tributaries (FEIS pgs. 3.6-30 -3.6-32).
Record of Decision 

ROD - 8 Lower West Fork Project

Ø Seven culverts present barriers to westslope cutthroat trout migration (FEIS 3.7-29). Replacing 

or removing these barriers would reconnect westslope cutthroat trout access to about 3.4 miles 

of spawning and rearing habitat. The improved access would allow genetic mixing between 

strains of westslope cutthroat trout and improve their resilience to environmental stressors.

Ø Terrace units developed in the late 1960s created high levels of ground disturbance. The units 

have regenerated and formed dense stands of commercial-sized trees. Thinning these stands 

provides an opportunity to augment soil rehabilitation on the terrace benches by actively 

decompacting the soil and covering them with 10-15 tons/acre of woody debris. Active 

decompaction will only be feasible on units with slopes less than 35 percent. On steeper slopes, 

10 to 15 tons/acre of woody debris will be left on the terrace benches. The high levels of woody 

debris increase soil moisture, moderate soil temperatures, and increase soil microbe populations 

and functions. 

Changing these resource conditions to maintain the ecological parameters under which they developed will 

allow more management flexibility of natural disturbances, specifically fire, when they occur. The 

proposed actions would change the existing resource conditions so they are closer to the desired conditions. 

They would also complement and extend the area of fuels reduction treatments in the Frasier Interface 

project (designed by the Forest Consensus Council), the School Point Ecoburn, and similar actions taken on 

private land. The objective is not to attain a specific desired condition and remain static, rather to create 

conditions where natural processes can occur without severe ecological consequences or large capital 

investments.

Soil, watershed, and fishery resources have residual effects from road system development and past harvest 

practices. This analysis provides an opportunity to evaluate these situations in the context of the planned 

activities and improve these resource conditions. The Water Quality Restoration Plan and Total Maximum 

Daily Loads for the Bitterroot Headwaters Planning Area

4.1 DECISION

(Restoration Plan) (MDEQ 2005) listed the West 

Fork River as impaired by sediment. Though the Restoration Plan did not identify any of the streams in the 

Lower West Fork analysis area as restoration priorities, it recommends that sediment from roads be reduced 

in the West Fork River Watershed (MDEQ 2005 pg. 182). 

I have decided to select Alternative 3-modified to include the following features of Alternative 2: 

Ø Include Unit 60 on the west side of the river as a commercial thin unit

Ø Retain herbicide use as described in Alternative 2 as an option for treating new invasive plant

populations

Ø Treat prescribed fire units in the WUI on the east side of the river as proposed in Alternative 2 

Ø Decommission NFSR 13841 from its junction with NFSR 74327

Ø Decommission NFSR 13424 from its junction with NFSR 13425

Unit 60 was not analyzed for treatment under Alternative 3 because the purpose of the alternative was to 

reduce fuels in the WUI on the west side of the West Fork River and Unit 60 is not within the WUI. 

However, Unit 60 abuts the Trapper-Bunkhouse analysis area and the Trapper-Bunkhouse unit adjacent to 

Unit 60 is scheduled for commercial thin. Thinning the unit in Trapper-Bunkhouse and not Unit 60 in 

Lower West Fork would create an unnatural visual and ecological division in the same vegetation type. 

There are no detrimental effects associated with treating Unit 60 and not treating it would diminish the 

landscape benefits of treatment in both project areas. 

Herbicide use was not analyzed under Alternative 3 to display the difference between vegetation treatments 

with and without herbicide use to control the spread of invasive plants. The same parameters for herbicide 

use as described in Alternative 2 would be applied to Alternative 3. Since less area will be treated than in 

Alternative 2, the potential need to use herbicides will be less and therefore, the effects of herbicide use 

will be less than described in Alternative 2. 
Record of Decision

Lower West Fork Project ROD - 9

Though the headwaters of Piquett Creek and East Piquett Creek have burned in the past 10 years, there is 

still the potential for crown fire in the WUI on the east side of West Fork River. Prescribed fire in Units 

64, 65, 69, 71, 72, and 73 would reduce fuels adjacent to private land and provide options when managing 

fires. 

In Alternative 3, NFSR 13424 and 13841 were proposed for decommission from their junctions with NFSR 

5723 and 5724, respectively. After closer inspection, it is apparent that this action would close access to 

other road systems without removing the drainage structures. Furthermore, closing the other road systems 

was not analyzed in this process. My decision is to decommission NFSRs 13424 and 13841 from their 

junctions as stated above, which would reduce the total road decommission project by about one mile 

(about 0.5 mile less decommissioning on each road). Current management direction would be followed on 

the road sections not decommissioned. 

The above modifications were analyzed under Alternative 2 and their effects would not exceed the degree 

of effects analyzed in that Alternative.

My decision will reduce fuels on approximately 4,131 acres using commercial thinning, non-commercial 

thinning, and prescribed fire (Table 1). Approximately 88% of the treatments will occur in the WUI (Fig. 

1, 2). About 1,741 acres will be commercially thinned using ground-based and skyline yarding systems 

(Table 1). Commercial thins occur on parts of the commercial thin units, however the entire unit 

understory will be thinned (non-commercial thin) and excess slash will be treated using prescribed fire. 

Fuels will be reduced on another 1,658 acres using prescribed fire only. Another 296 acres in existing 

plantations will be non-commercially thinned. Approximately 1.8 miles of temporary road and 1.6 miles of 

tracked line machine (TLM) trail will be constructed to access timber. Individual road lengths vary 

between 1,200 and 2,100 feet. 

My decision includes the application of the design features and mitigation measures described in the FEIS 

and summarized in Chapter 2 (FEIS pgs. 2-18 – 2-25) and Appendix A of this Record of Decision. About 

18 miles of road will be stored and 26 miles decommissioned (Table 2, FEIS pg. 3.6-31, Table 3.6-13). 

Thirty-three culverts will be removed from road-stream crossings, 23 of which contribute sediment to 

streams. Storing or decommissioning 11.3 miles of road are mandatory to off-set potential short-term 

timber sale effects (Table 3, FEIS Table 2-4). This mitigation would remove 18 culverts, 12 of which 

contribute sediment to streams. The remaining roads will be decommissioned or stored using appropriated 

or partnership funds. Table 4 provides a summary of the treatments in Alternative 3, modified.

Table 1: Unit Treatments under Alternative 3-modified

Unit 

No. Treatment* Area(acre)

WUI 

Area 

(acre)

Yarding Method (acre) Temp. 

Roads1

(ft)

TLM2 Trail 

(ft2) Ground Skyline TLM

1 Commercial Thin with underburn 239 239 64 26 31 1,246 404

2 Commercial Thin with underburn 197 197 76 104 0 N/A3 N/A

3 Commercial Thin with underburn 163 163 98 58 7 N/A 873

4 Commercial Thin with underburn 142 142 52 0 0 N/A N/A

5 Commercial Thin with underburn 35 35 12 21 0 N/A N/A

6 Commercial Thin with underburn 35 35 35 0 0 N/A N/A

7 Commercial Thin with underburn 25 25 0 19 10 N/A N/A

8 Commercial Thin with underburn 130 130 43 62 25 1,454 1,035

9 Commercial Thin with underburn 109 109 16 62 15 1,284 N/A

10 Commercial Thin with underburn 55 55 11 40 0 N/A N/A

11 Commercial Thin with underburn 33 33 30 3 0 N/A N/A

12 Commercial Thin with underburn 125 125 93 13 19 1,863 598

14 Commercial Thin with underburn 19 0 3 16 0 N/A N/A

21 Commercial Thin with underburn 18 0 0 18 0 N/A N/A

25 Commercial Thin with underburn 7 0 2 5 0 N/A N/A
Record of Decision 

ROD - 10 Lower West Fork Project

Unit 

No. Treatment* Area(acre)

WUI 

Area 

(acre)

Yarding Method (acre) Temp. 

Roads1

(ft)

TLM2 Trail 

(ft2) Ground Skyline TLM

27 Non-commercial Thin 4 0 0 N/A N/A N/A N/A

32 Prescribed Fire 131 131 N/A N/A N/A N/A N/A

33 Prescribed Fire 282 237 NA N/A N/A N/A N/A

34 Commercial Thin with underburn 119 119 43 0 0 N/A N/A

35 Commercial Thin with underburn 35 35 5 0 31 N/A 1,814

60 Commercial Thin with underburn 140 0 102 28 N/A 1,322 N/A

60A Prescribed Fire 31 0 N/A N/A N/A N/A N/A

61 Commercial Thin with underburn 418 418 131 145 8 2,112 1,812

61A Prescribed Fire 414 415 N/A N/A N/A N/A N/A

62 Commercial Thin with underburn 66 66 19 47 0 N/A N/A

63 Prescribed Fire 20 20 N/A N/A N/A N/A N/A

63B Prescribed Fire 32 32 N/A N/A N/A N/A N/A

64 Prescribed Fire 246 246 N/A N/A N/A N/A N/A

65 Prescribed Fire 40 28 N/A N/A N/A N/A N/A

69 Prescribed Fire 27 27 N/A N/A N/A N/A N/A

70 Prescribed Fire 199 199 N/A N/A N/A N/A N/A

71 Prescribed Fire 70 49 N/A N/A N/A N/A N/A

72 Prescribed Fire 4 4 N/A N/A N/A N/A N/A

73 Prescribed Fire 2 2 N/A N/A N/A N/A N/A

74 Prescribed Fire 4 4 N/A N/A N/A N/A N/A

75 Non-commercial thin 20 0 N/A N/A N/A N/A N/A

80 Non-commercial thin 24 0 N/A N/A N/A N/A N/A

81 Commercial Thin with underburn 25 25 0 25 0 N/A N/A

82 Non-commercial thin 11 11 N/A N/A N/A N/A N/A

83 Non-commercial thin 14 14 N/A N/A N/A N/A N/A

84 Non-commercial thin 2 2 N/A N/A N/A N/A N/A

85 Non-commercial thin 15 15 N/A N/A N/A N/A N/A

86 Commercial thin 23 23 0 23 0 N/A N/A

87 Non-commercial thin 38 38 N/A N/A N/A N/A N/A

88 Commercial Thin with underburn 30 29 7 24 0 N/A N/A

89 Commercial Thin with underburn 61 0 0 51 10 N/A 1,046

90 Commercial Thin with underburn 38 0 3 36 0 N/A N/A

91 Non-commercial thin 28 28 N/A N/A N/A N/A N/A

92 Non-commercial thin 27 0 N/A N/A N/A N/A N/A

93 Non-commercial thin 12 0 N/A N/A N/A N/A N/A

94 Non-commercial thin 7 7 N/A N/A N/A N/A N/A

95 Non-commercial thin 43 43 N/A N/A N/A N/A N/A

96 Non-commercial thin 23 23 N/A N/A N/A N/A N/A

97 Non-commercial thin 4 4 N/A N/A N/A N/A N/A

98 Non-commercial thin 11 0 N/A N/A N/A N/A N/A

99 Commercial Thin with underburn 16 16 0 0 16 N/A 927

100 Prescribed Fire 30 30 N/A N/A N/A N/A N/A

101 Non-commercial thin 9 9 N/A N/A N/A N/A N/A

102 Non-commercial thin 4 0 N/A N/A N/A N/A N/A

TOTALS 4,131 3,637 743 826 172 9,281 8,509

Percentage 851 432 49 8 (1.8 mi) (1.6 mi) 1

Percentage of area treated

2

Percentage of harvest area


Record of Decision

Lower West Fork Project ROD - 15

Table 2: Stored or Decommissioned Roads under Alternative 3-modified

Road Number Milepost Description Culverts 

Removed

Contributing 

Culverts Removed

363, Piquet Cr. 5.1-6.8 Storage 0 0

363, West Fork near Baker Cr. 0.0-3.0 BMP Improvements 0 0

5724, Piquett 0.0-3.7 BMP Improvements 0 0

13411, East Piquett1 1.6-2.4 Storage 4 2

13411, East Piquett1 2.4-2.8 Decommission 1 0

13421, Piquett 0.0-0.6 Decommission 0 0

All Haul Routes Entire 

Length

Reshape and maintain drain dips; under 

contract and complete before contract closes

13422, Piquett 0.0-0.2 Decommission 0 0

13423, Piquett 0.0-1.7 Storage 1 0

13423, Piquett 1.7-1.9 Decommission 0 0

13424, Piquett1 0.2-3.1 Decommission 4 2

13430, Piquett 0.0-4.2 Decommission 1 1

13434, Piquett 0.0-2.7 Storage 1 1

13434, Piquett 2.1-2.7 Decommission 1 1

13456, East Piquett 0.4-1.6 Storage 0 0

13457, Near Baker1 0.0-1.8 Storage 0 0

13464, East Piquett 1.7-2.3 Decommission 0 0

13465, East Piquett 0.0-1.6 Decommission 1 1

13466, Pierce1 0.0-0.6 Storage 3 2

13828, Troy, Lavene 0.0-0.9 Storage 1 1

13829, Violet 0.0-3.6 BMP Improvements 0 0

13830, Violet1 0.0-1.6 Storage 2 2

13831, Violet1 0.0-1.3 Decommission 2 2

13832, Piquett 0.6-0.9 Decommission 0 0

13834, Piquett 0.0-0.6 Decommission 1 0

13836, East Piquett1 0.0-2.4 Decommission 2 2

13837 Repair sediment sources

13838, East Piquett 0.0-0.6 Decommission 1 1

13839, Piquett 0.6-0.8 Decommission 0 0

13840, Piquett 0.0-1.8 Decommission 1 0

13841, Piquett 0.0-1.2 Decommission 1 0

13842, Piquett 0.0-1.3 Decommission 1 1

13883, East Piquett 0.0-0.1 Storage 0 0

62416, Lavene 0.0-0.6 Storage 1 1

74006, Ward 0.0-1.2 Decommission 0 0

74023, Barn Draw 1.0-1.8 Decommission 1 1

74313, East Piquett 0.0-0.2 Decommission 1 1

74319, East Piquett 0.0-0.8 Storage 0 0

74320, East Piquett 0.0-0.2 Storage 0 0

74321, Piquett1 0.0-0.7 Decommission 1 1

74339, Castle 0.0-1.7 Storage 0 0

74347, Pierce 0.0-0.2 Decommission 0 0

74357, Christisen 0.0-0.3 Decommission 0 0

74605, Caste 0.0-1.4 Storage 0 0

74606, Castle 0.0-0.8 Storage 0 0

74611, Castle 0.0-0.1 Storage 0 0

Total culverts removed

Estimated Sediment Reduction (1.7tons*23)

33 232

39.1 ton less 1 Included in stewardship contract and completed prior to the contract closure. 2 BMP work assumed neutral
Record of Decision 

ROD - 16 Lower West Fork Project

Table 3: Mandatory Stewardship Road Treatments under Alternative 3-modified. 

The adaptive management protocol developed for the 65-acre portion of Unit 1 with detrimental soil 

disturbance will be applied. This protocol reduces ladder fuels, provides coarse woody debris, and 

increases crown spacing without the use of heavy equipment. Heavy equipment in this portion of Unit 1 

might increase soil compaction above Region 1 soil standards. Initially, the area will be thinned from 

below and the slash will be lopped and scattered to prevent beetle infestation. The slash will be left on the 

ground at least one year to allow nutrients to leach into the soil. The slash will be burned and the area resurveyed to assess residual coarse woody debris on the site. The coarse woody debris goal is 15-20 tons 

per acre. If residual coarse woody debris is below the required level, larger trees will be felled and left on 

site. The treatment emphasis will be to thin Douglas-fir and retain large ponderosa pine. Douglas-fir logs 

greater than 17 inches diameter and longer than six feet are preferred as coarse woody debris because 

Douglas-fir decays at a slower rate than ponderosa pine and stays on the soil surface longer. 

Thinning larger trees from the overstory increases crown spacing and coarse woody debris in larger 

diameter classes. Limbs and treetops may needed to be piled and burned if the fine fuel load is too high

following the last thinning entry. 

Table 4: Summary of Activities for Alternative 3-modified

Activity Acres (% of total area treated)

Total Number of Treatment Units 60

Treatments Area in WUI (acres) 3,639 (85%)

Proposed Treatments:

 Commercial Thin 2,303 (56%)

 Prescribed Burn 1,532 (37%)

 Small Tree Thin (Plantations) 296 (7%)

 Research 199 (5%)

Total Acres Treated 4,131

Yarding Systems:

 Skyline 998 (57%)

 Tractor 743 (43%)

Total Commercial Treatments 1,741

Temporary Road Construction (miles) 1.8

Tracked Line Machine (TLM) Trail (miles) 1.6

Roads to be decommissioned (miles) 26

Mandatory Roads to be decommissioned 11.3

Estimated Timber Harvest Volume (thousand cubic feet, CCF) 11,700 (5.4 mmbf1) 1 mmbf = million board feet

Road Number Watershed Treatment Length (miles)

13411 East Piquett Storage 0.8

13411 East Piquett Decommission 0.4

13421 Piquett Decommission 0.7

13424 Piquett Decommission 2.4

13457 East Piquett Storage 1.8

13466 Pierce Storage 0.6

13830 Violet Storage 1.6

13831 Violet Decommission 1.3

13836 East Piquett Decommission 2.4

13837 Piquett Repair sediment sources N/A
Record of Decision

Lower West Fork Project ROD - 17

5.1 ALTERNATIVES CONSIDERED 

Three alternatives were analyzed in detail in the FEIS. These are briefly described below. Table 5 shows a 

comparison of activities by alternative, including the chosen alternative.

Table 5: Comparison of Activities by Alternative

5.1.1 ALTERNATIVE 1 – NO ACTION (FEIS PP. 2-5).

Under Alternative 1, current management would continue in the analysis area. No treatments are 

prescribed in Alternative 1 that would reduce potential crown fire, improve forest resiliency, or watershed 

condition. Though no management activities are proposed under this alternative, environmental changes 

will continue in the analysis area. 

5.1.2 ALTERNATIVE 2 - PROPOSED ACTION (FEIS PP. 2-5 TO 2-12).

Alternative 2 was developed to meet the Purpose and Need of the project. It would have treated 

approximately 5,056 acres on National Forest System land. Eighty-five percent of the treatments would 

occur in the WUI. The proposed treatments would have been a combination of commercial thinning, small 

tree thinning, and prescribed burning. Approximately 49% of the treatment area would produce 

commercial timber volume estimated to be about 7.5 million board feet (MMBF). About 2.2 miles of 

temporary roads and 1.7 miles of TLM trail would have been constructed. This alternative would have 

stored almost 19 miles of road and decommissioned another 10 miles. Properly closing these roads would 

have removed 22 culverts of which 16 contribute sediment to streams. About 11.6 miles of road would 

Activity Alt. 1 Alt. 2 Alt. 3 Alt. 3 – modified

Total Number of Treatment Units 0 76 51 60

Acres of Treatments in Wildland Urban Interface (% of 

total acres treated) 0 4,290 (85%) 3,277 (91%) 3,639(85%)

Proposed Treatments in acres (% of total acres treated)

Commercial Thin with underburn 0 3,057 (60%) 2,163 (60%) 2,303 (56%)

Prescribed Burn only 0 1,703 (34%) 1,140 (32%) 1,532 (37%)

Small Tree Thin (Plantations) 0 296 (6%) 296(8%) 296 (7%)

Research (included in Prescribed burn) 0 199 (4%) 199 (6%) 199 (5%)

Total Acres Treated 5,056 3,599 4,131

Yarding Systems (acres) (% of harvest)

Skyline 0 1,083 (43%) 798 (47%) 826 (47%)

TLM 0 366 (15%) 172 (10%) 172 (10%)

Tractor 0 1,044 (42%) 743 (43%) 743 (43%)

Roads Management

Temporary Road Construction (miles) 0 2.2 1.5 1.8

TLM trail (miles) 0 1.7 1.6 1.6

Roads Decommissioned or stored with timber sale(miles) 0 11.6 11.8 11.8

Culvert removed/sediment contributors 0 15/11 18/12 18/12

Road Storage 19 18 18

Total Road decommission (miles) 0 10 27 26

Total Culverts removed/sediment contributors 0 22/16 33/23 33/23

Fish Passage Barriers removed/replaced 0 7 7 7

Fish screens installed 0 2 2 2

Soil Restoration 0 329 382 382

Estimated Timber Harvest Volume (thousand board feet, 

MBF) 0 7,500 5,100 5,500
Record of Decision 

ROD - 18 Lower West Fork Project

have been stored or decommissionied as part of the timber sale. The remaining work would be funded by 

appropriated or partnership funds.

Five culverts that block fish passage would also be replaced or removed. Soil restoration would be initiated 

in harvest units 1, 3, and 12 and on 297 acres of terraced plantations. 

5.1.3 ALTERNATIVE 3 (FEIS PP. 2-12 TO 2-15).

Alternative 3 was designed to respond to the public concern that fires in 2000 and the Rombo fire have 

treated fuels on the east side of the West Fork River and that additional treatment is not necessary for 

community fire protection in the WUI. Alternative 3 would have treated approximately 3,599 acres of

National Forest System land. Ninety one percent of the treatments would occur in the WUI. The proposed 

treatments would have been similar to those described for Alternative 2. Approximately 48% of the 

treatment area would produce commercial timber volume estimated to be about 5.1 MMBF. Approximately 

1.5 miles of temporary roads and 1.6 miles of TLM trail would have been constructed. This alternative 

would have stored about 18 miles of road and decommissioned another 27 miles. Properly closing these 

roads would have removed 33 culverts of which 23 contribute sediment to streams. About 11.8 miles of 

road would have been stored or decommissionied as part of the timber sale. The remaining work would be 

funded by appropriated or partnership funds. 

Treatments to benefit the fisheries would have been the same as in Alternative 2. Soil restoration strategies 

would also have been the same except in Unit 1. The portion of Unit 1 with high amounts of soil 

compaction would not be commercially thinned. Instead, the progressive strategy would achieve the fuel 

load reduction and stand enhancement objectives in the purpose and need. The strategy consists of:

Ø thinning from below

Ø lopping the slash to prevent beetle infestation

Ø letting nutrients leach from the slash for at least a year

Ø burn the slash

Ø assess coarse woody debris level with a goal of 15-20 tons/acre

Ø thin larger trees from the mid-story, if necessary

5.2 ALTERNATIVES CONSIDERED BUT ELIMINATED (FEIS PP. 2-17)

During project development, and in response to comments submitted on the DEIS, six other alternatives 

were considered but not analyzed in detail. These alternatives, and the reasons for not analyzing them in 

detail, are described below.

5.2.1 FOCUS FUEL TREATMENTS IN THE HOME IGNITION ZONE RATHER THAN 

EXTENSIVE WILDLAND FUEL MANAGEMENT 

This alternative was not considered in detail because it would treat fuels on only a tiny fraction of the 

National Forest. The effects of this alternative would be indistinguishable from the No Action alternative. 

This alternative would not meet the purpose and need because it would not:

Ø Reduce fuel loads enough to lower crown fire hazard

Ø Improve ponderosa pine resilience

Ø Promote the representation of shade intolerant trees species in stands. 

5.2.2 REMOVE OR FIX ALL ROADS THAT CAUSE SOIL AND WATER PROBLEMS, OR 

ARE NOT NEEDED FOR FUTURE MANAGEMENT

Alternatives 2 and 3 adequately address this issue. The ID Team used the Roads Analysis process to 

determine the roads not needed for future management. The FEIS discloses the cost of fixing all roads that 

cause soil and water problems. The arterial roads that encroach on streams in the analysis area (Roads 363 
Record of Decision

Lower West Fork Project ROD - 19

and 5630 along Pierce and Lavene creeks, for example) have been graveled to reduce sediment production. 

Little more can be done to reduce sediment production from these roads other than paving or relocation. 

Paving or relocation is infeasible due to topographic constraints and high costs.

5.2.3 DROP ALL UNITS WHERE TREATMENTS ARE PROPOSED FOR FOREST HEALTH 

REASONS, OR FOR GENERATING MONEY TO DO OTHER WORK

None of the treatment units were proposed exclusively for forest health reasons, or for generating money. 

All of the treatment units were designed to improve stand resiliency to fire and insect activity. Therefore, if 

all of the units proposed to improve stand resiliency were dropped, the alternative would be the same as the 

No Action alternative, which is analyzed.

5.2.4 DO NOT INCLUDE ANY COMMERCIAL LOGGING IN ROADLESS AREAS, BUT DO 

INCLUDE THE USE OF PRESCRIBED FIRE

Alternatives 2 and 3 adequately address this alternative. Both alternatives propose the use of prescribed 

fire in inventoried roadless areas, and neither alternative proposes commercial harvest in inventoried 

roadless areas.

5.2.5 DEVELOP A WATERSHED RESTORATION ALTERNATIVE, OR AT LEAST INCLUDE 

WATERSHED RESTORATION ELEMENTS IN ALL OF THE REASONABLE 

ALTERNATIVES.

Alternative 3 was developed in response to this recommendation. Watershed restoration elements are also 

included in Alternative 2. 

5.2.6 REDUCE FUELS THROUGH TIMBER HARVEST AND SLASH DISPOSAL WITHOUT 

THE USE OF PRESCRIBED FIRE OR PILE BURNING.

This alternative would not treat the prescribed fire units or adequately reduce fuel loads. Not treating the 

prescribed fire units would decrease the fuels management effectiveness at the landscape-level (Arno and 

Fiedler 2005, Finney et al. 2005) by maintaining forest conditions that could carry fire and threaten 

resources in and adjacent to the WUI. 

Thinning forests creates slash or woody material with little to no commercial value. Some of this material 

has value for replenishing soil nutrients and other soil characteristics, however too much can increase fuel 

loads and fire hazards. Slash can be ground into chips but this requires whole tree yarding, which is not 

feasible in some units. Also, chip vans typically have a wider turning radius than log trucks and may not be 

able to access some units. The nearest chip market is 100 miles from the analysis area but is not operating 

at this time. Under Alternatives 2, 3, and 3 – modified, chipping is an option if the market is available and 

the units are accessible (FEIS pg. 2-8, 2-14). 

Stephens et al. (2009) found the effectiveness of mechanical thinning to reduce passive and active crown 

fire potential is dependent on the type of harvest system used, and the activity fuels remaining after harvest. 

Whole tree harvest systems cause little increase in 1-, 10-, and 100-hour fuels while cut-to-length systems 

greatly increase surface fuels in these classes. Stephens et al. (2009) found that mechanical treatments 

followed by prescribed burning or pile burning were the most effective treatment for reducing crown fire 

potential and predicted tree mortality. Post-wildfire studies indicate that mechanically treated stands 

without surface fuel treatments burned with higher intensity than those mechanically treated followed by 

prescribed fire (Skinner et al. 2004, Cram et al. 2006, Schmidt et al. 2008). 

For these reasons, this alternative would not meet the purpose of reducing fuel loads and crown fire 

potential. 
Record of Decision 

ROD - 20 Lower West Fork Project

6.1 RATIONALE FOR MY DECISION 

In selecting Alternative 3-modified, I determined that my decision is consistent with all laws, regulations, 

and policies. I considered the potential cumulative effects and reasonably foreseeable activities. I believe 

my decision provides the best balance of management activities to respond to the purpose and need, public 

comments, and environmental and social issues while complying with all applicable laws and regulations. 

I base my conclusion on a review of the record that shows a thorough review of relevant scientific 

information, consideration of responsible opposing views, and the acknowledgement of incomplete or 

unavailable information, scientific uncertainty, and risk. For example, soil surveys in Unit 1 indicate that 

42 acres of the Unit has 19% detrimental soil disturbance (DSD). The soil scientist recommended winter 

logging for the highly compacted soils in Unit 1. Forest monitoring supported by scientific literature 

indicates that winter ground-based harvest causes about 1% DSD (FEIS 3.5-18). Though mitigation 

measures require re-using skid trails and leaving 15-20 tons of coarse woody debris on the site, there is a 

risk that soil compaction would increase in the short-term. In response to a comment on the DEIS, I 

directed the ID Team to develop an alternative treatment that would meet the purpose and need for the 

project without increasing DSD. The alternative treatment analyzed in Alternative 3 of the FEIS does not 

increase DSD because heavy equipment is not used (FEIS 3.5-20). It achieves the purpose and need by 

thinning the understory and possibly the overstory, treating the smaller fuels after nutrients leach into the 

soil, and leaving the larger woody debris for long-term soil productivity. Throughout the FEIS, the 

scientific basis is referenced as it supports the purpose and need, the actions developed to respond to the 

purpose and need, and the effects analysis of the actions included in my decision. 

The criteria I relied upon to make my decision on this project include:

Ø Achievement of the project purpose and need

Ø Relationship to environmental and social issues and public comments

My decision reduces the severity of fire on National Forest System lands adjacent to private property, and 

supports the Bitterroot Community Wildfire Protection Plan. 

6.1.1 MEETING THE PURPOSE AND NEED

As noted in Section 3.1 of this document, the purposes for undertaking the Lower West Fork project are: 

Ø Reduce fuel loads and lower crown fire hazard in low elevation ponderosa pine/Douglas-fir 

forests

Ø Improve forest resilience to natural disturbances (fire, insects, disease); particularly the 

resilience of large diameter ponderosa pine trees 

Ø Maintain or increase shade intolerant species, specifically ponderosa pine

Ø Improve overall soil, watershed, and fisheries conditions by reducing road effects and 

rehabilitating degraded soils in historic harvest units and terraced lands.

Measurement indicators (Table 6) were developed for each of the purpose and need statements to indicate 

how each alternative responds to the statements (FEIS pg. 2-4, 2-16). The following section describes the 

purpose and need statements, lists the measurement indicators, and presents the results for each of the 

alternatives considered in detail. I believe the long-term benefits of improving forest conditions, reducing 

crown fire potential, and restoring the natural fire regime override the poor economics of this project. The 

currently poor market conditions may improve by the time the project is prepared for sale or the project 

may be delayed until market conditions improve. The analysis includes soil and watershed rehabilitation 

projects for which funds are available or that can better compete for funds since they are analyzed through 

the NEPA process. These projects will augment the natural soil rehabilitation and improve watershed 

conditions.
Record of Decision

Lower West Fork Project ROD - 21

Table 6: Comparison of Measures to Meet the Purpose and Need of the Lower West Fork Project

1 Represents area of commercial thin treatments. Though non-commercial thin treatments reduce stocking, they do not change the 

structure of the unit.

REDUCE FUEL LOADS AND LOWER CROWN FIRE HAZARD IN LOW ELEVATION 

PONDEROSA PINE/DOUGLAS-FIR FORESTS

The Bitterroot National Forest has been altered by 100 years of fire suppression, insect and disease 

outbreaks, and logging (Hessburg et al. 1994). The vegetation structure in most of the project area has 

shifted to dense, overstocked stands that are at increasing risk of stand-replacing fires. Large areas of 

unburned fuel exist in the project area that, in the event of a wildfire, could pose a considerable risk to 

firefighters, the public, and natural resources. 

The fires of 2000 burned over 307,000 acres on the Bitterroot NF causing the loss of residences and 

property and the evacuation of over 1,000 homes. The fires of 2000 burned a portion of the Piquett Creek 

drainage, but most of the Lower West Fork analysis area did not burn in 2000. In 2007, the Rombo fire 

covered about 29,000 acres and burned 24,700 acres, including much of the upper half of the Piquett Creek 

drainage. The Rombo fire did not pose as great a threat to life and property as the fires in 2000 because it 

started in the higher elevations. However, the suppression cost of this fire was 7.2 million dollars. The 

Lower West Fork analysis area surrounds private land along the West Fork River. A large fire, or multiple 

ignitions in one day on the West Fork face has the potential to overwhelm suppression forces and travel 

unimpeded to the Forest Service/private property boundary.

Addressing this situation is a primary purpose of this project. Taking actions to reduce fuels in the project 

area would set the stage for fire to play a more natural role, which historically was non-stand replacing with 

short-to-moderately short fire free interval. To achieve this purpose, there is a need to reduce existing fuel 

loads, including live trees and dead and down woody material. Fire type was the measure chosen to 

evaluate the effects of the proposed treatments on fuels and fire behavior. 

Purpose and Need Measure Alt. 1 Alt. 2 Alt.3 Alt.3 - modified

Area of reduced crown fire behavior (acres) 0 1,330 886 978

Area of reduced stocking (acres) 0 2,789 2,009 2,037

Area of reduced forest structure change1 (acres) 0 2,493 1,713 1,741

Area of ponderosa pine treated 0 2,614 1,829 1,870

Area treated in the WUI 0 4,290 3,277 3,637

Part- and Full-time job contribution over the life of the 

project 0 170 121 121

Income contribution over life of the project) ($) 0 5.6 million 4.0 million 4.0 million

Revenue available for resource improvement ($) 0 140,000 100,400 100,400

Expected funding needed for implementation of 

mandatory activities ($) 0 581,100 492,800 492,800

Expected funding needed for implementation of 

mandatory activities and all optional stewardship 

activities ($)

0 1,656,600 1,441,900 1,441,900

Reduced long-term sedimentation (tons/year) 0 27 39 39

Decommissioned roads (miles) 0 10 27 26

Stored roads (miles) 0 19 18 18

Stream crossings removed 0 23 33 33

Fish barriers eliminated 0 7 7 7

Soil rehabilitation in terraced plantations (acres) 0 297 297 297

Soil rehabilitation in units with historic disturbance 

(acres) 0 32 85 85
Record of Decision 

ROD - 22 Lower West Fork Project

Alternative 2 reduces potential crown fire behavior the most (1,330 acres) followed by Alternatives 3 –

modified (978 acres) and 3 (886 acres) (Table 6). The potential for crown fire to occur would continue to 

increase in Alternative 1.

The west side of the West Fork River is the highest priority for treatment because the terrain and vegetation 

are fairly uniform. Only one fire has occurred in the area since 1979. All of the action alternatives treat 

this area similarly. The difference between alternatives is the treatments on the east side of the West Fork 

River. The east side of the river has more broken terrain and more area previously harvested using the 

clearcut silvicultural system. The less uniform stands and topography create more barriers to fire spread. 

In addition the Rombo Fire and fires in 2000 burned most of the analysis area up to the WUI. Alternative 2 

treats the most area using a combination of prescribed fire and commercial thin followed by an underburn. 

Alternative 3 treats only the terrace units. This treatment may interupt fire behavior but it but would not be 

as effective as Alternative 2. Alternative 3-modified allows for prescribed burning that would augment the 

treatment in the terrace units. The ID Team discovered through the analysis process that the Piquett 

drainage is vulnerable to channel changing events because of the amount of forest canopy lost during the 

Rombo Fire. In addition, the recent fires have reduced thermal cover and old growth habitat. Not 

harvesting timber in these units would offset the effects of the fires. Under these circumstances, I believe 

that Alternative 3-modified provides appropriate reductions in potential crown fire that will provide 

adequate fire management options in response to ignitions and protect vulnerable resource conditions and 

habitat components. 

IMPROVE PONDEROSA PINE FOREST RESILIENCY TO NATURAL DISTURBANCE,

Stands in the Lower West Fork project area are a product of succession in the absence of disturbance. 

Stand densities have increased which has decreased tree vigor and increased fuel continuity. Declining tree 

vigor increases forest susceptibility to insects and disease, and higher tree mortality. Increasing stand 

density also increases the fuel continuity and provides structure for the development of crown fires. 

Ponderosa pine and ponderosa pine/Douglas-fir stands historically experienced frequent low-to-mixed 

intensity fires. This fire regime created landscapes resilient to fire, insects, and disease pathogens. Not only 

does the increase in tree density increase the flammability of the forest, but it increases water and nutrient 

competition among trees, shrubs, and other forest plants and predisposes the forest to disease and insect

attacks. The area of reduced stand density, especially in the ponderosa pine and ponderosa pine/Douglasfir forests was the indicator used to determine resiliency. Commercial thinning reduces stocking and 

favors disease-resistant trees, which improve tree vigor and resiliency. Alternative 2 reduces stocking the 

most (Table 6) followed by Alternative 3-modified and Alternative 3. Stocking is not reduced under 

Alternative 1 and stand density will continue to increase in the analysis area. 

Again, the Alternatives treat the same units on the west side of the West Fork River, except Alternative 3 

does not treat Unit 60. On the east side of the River, the terrace units are the only units commercially 

thinned in Alternative 3 or Alternative 3-modified. Not thinning the stands commercially thinned under 

Alternative 2 on this side of the river may off-set recent losses in thermal cover in the adjacent burned 

areas. The stands will become increasingly at risk for disease and insect attacks but treatments in the 

terrace units and prescribed fire units may buffer this risk. 

As described in the Economics and Social Analysis section of the FEIS, the timber program on the 

Bitterroot National Forest has declined substantially over the last twenty years. However, even at the 

current level, timber from the Forest plays an important role in the wood products economy of Missoula 

and Ravalli Counties. The trees harvested to reduce stocking levels and, consequently, reduce the risk of 

stand-replacing wildfires, have commercial value, which will contribute to the local economy. 

The ID Team selected two measurement indicators to compare the alternatives in terms of their effect on 

economic opportunities. They are total employment, expressed as jobs, and total labor income. It is 

important to note that these are not new jobs or income, but rather jobs and labor income attributed to the 

project. 
Record of Decision

Lower West Fork Project ROD - 23

With respect to total employment, Alternative 2 would contribute 170 part- and full-time jobs over the life 

of the project, followed by Alternative 3 with 121 jobs over the life of the project. Alternative 3-modified

would be similar to Alternative 3 because timber harvest on the east side of the river is similar to 

Alternative 3 and the road decommissioning and storage is essentially the same.

With respect to total labor income, Alternative 2 would result in $5.6 million dollars spread over the life of 

the project, followed by Alternative 3 with $4.0 million dollars spread over the life of the project. Again, 

Alternative 3-modified would be similar to Alternative 3 because the treated areas are similar and the 

watershed, soils and fisheries projects are the same. Alternative 1 would not result in any total labor 

income. Under current market conditions, this project is unlikely to generate adequate funds to cover all 

the stewardship costs. However, allocated and partnership funds are available to pay for most watershed, 

soil, and fisheries projects not associated with the timber sale and having these projects analyzed in a 

NEPA document improves their potential to be funded. 

MAINTAIN OR INCREASE SHADE INTOLERANT SPECIES

The dry, lower elevations are composed of mixed Douglas-fir and ponderosa pine in well-stocked or overstocked stands with increasing levels of Douglas-fir regeneration in the understory. Fire was an important 

agent that controlled forest density and species composition. These moderately warm, dry grasslands and 

cool upland sites had high fire frequencies and low to mixed intensity fire regimes. Fire suppression 

initiated the species composition shift in most of the ponderosa pine forest type to forest dominated by 

more shade tolerant species such as Douglas-fir and grand fir. Fire suppression reduced fire frequency and 

created conditions for shade tolerant species to encroach and out-compete less shade tolerant species. 

Reducing the stand density to favor retention of the large ponderosa pine and to a lesser extent, the large 

Douglas-fir will allow fire to function at an intensity that will not damage the forest components. The 

measurement indicators selected to compare the alternatives are area of ponderosa pine habitat treated and

area of reduced stand density. As with the previous measures, Alternative 2 treats the most area and 

reduces the density of the most stands. Alternative 3 treats the least area and the fewest stands. Alternative 

3-modified is similar to Alternative 3, though this alternative treats slightly more area. Again, Alternative 1 

does not treat any stands so ponderosa pine representation in stands would continue to decline. 

The main difference between the action alternatives is the treatment of areas on the east side of the West 

Fork River. Only the terrace units are thinned on the east side of the River in Alternatives 3 and 3–

modified though ponderosa pine stands will be maintained in the prescribed fire units under Alternative 3–

modified. 

IMPROVE OVERALL SOIL, WATERSHED, AND FISHERIES CONDITIONS BY REDUCING 

ROAD IMPACTS AND REHABILITATING SOILS ON TERRACED LANDS IN THE AREA.

Road sediments reduce water quality and channel conditions by increasing the amount of fine sediments in 

the stream, which settles into the stream substrate, reduces the volume of pools, and increases bank erosion. 

The Restoration Plan lists the West Fork River as impaired (MDEQ 2005) by sediment and thermal 

modification. The Restoration Plan recommends reductions in road sediment sources. The number of 

stream crossings removed and the miles of road decommissioned or stored are the two measurement 

indicators. 

Streams and Fish

Alternatives 3 and 3 – modified decommission and store the most miles of road and remove the most 

culverts. Alternative 2 is similar to Alternatives 3 and 3–modified in the miles of road stored but 

decommissions 10 miles of road in contrast to the 27 and 26 miles of road decommissioned in Alternatives 

3 and 3–modified, respectively. Similar amounts of road are stored or decommissioned as part of the 

timber sale (Table 6). Appropriations or partnerships will fund the roadwork not associated with the timber 

sale. 
Record of Decision 

ROD - 24 Lower West Fork Project

Soil conditions in three proposed commercial thinning units are near or exceed Region 1 Soil Quality 

Standards. Rehabilitation by increasing the amount of fine and coarse wood on the soil for future soil 

development, decompacting soils degraded by past ground-based logging operations, or a combination of 

these treatments would improve soil quality. 

Rehabilitating Detrimental Soil Disturbance

The project area contains approximately 297 acres of terrace plantations created in the late 1960s to 

improve tree survival and growth. The construction of terraces created high levels of soil disturbance as 

dozers cut benches across the recently clearcut slopes. The soils cut from the benches were side cast down 

slope on risers between benches. Dozer operations created highly compacted soil conditions on the terrace 

benches. Soil monitoring of the terraces indicate these units have 50 to 60 percent detrimental soil 

disturbance, which exceeds Region 1 Soil Quality Standards. The two measures indicating differences 

between alternatives are the area of soil improvement in past harvest units and the area of soil improvement 

on terrace plantations. All the alternatives treat the same area of terrace plantations and Alternative 2 treats 

32 acres of past harvest units while Alternatives 3 and 3–modified treat 85 acres. The difference between 

alternatives is not the absolute area treated but the method of treatment. My preference is in the methods 

used to treat the compacted soils in Unit 1 as described in Alternatives 3 and 3–modified. I believe this 

treatment would augment soil rehabilitation without the risk of incurring more compaction. 

IMPROVE AQUATIC CONNECTIVITY

The fishery in the Lower West Fork analysis area does not meet desired conditions, primarily because 

several culvert barriers fragment bull trout and westslope cutthroat trout populations; and non-native trout 

competitors are present throughout the West Fork River and much of Piquett and East Piquett creeks. 

The number of fish barriers replaced or removed is the measurement indicator selected to address this 

Purpose and Need item. Alternatives 2, 3, and 3–modified all remove or replace the same culvert on the 

same streams. No culverts are removed or replaced under Alternative 1.

6.1.2 ADDRESSING ISSUES AND PUBLIC CONCERNS

I considered the comments received on the DEIS, and directed the ID Team to incorporate changes to the 

FEIS as appropriate. Refer to the Summary of Changes between Draft and Final EIS in the FEIS. Chapter 

4 of the FEIS provides more thorough responses to the comments on the DEIS and the comment letters are 

provided in Appendix G of the FEIS.

The following are the major concerns raised by the public in their responses to scoping the DEIS, and 

during public field trips and public meetings. I have summarized how the ID Team addressed them

through the analysis process.

FISHERIES AND WATERSHED 

The primary concerns raised by the public focused on the funding of proposed watershed improvement 

mitigations and opportunities. 

The funding of watershed and fisheries improvements are discussed in alternative descriptions and the 

Chapter 3 watershed and fisheries sections of the FEIS. They are also considered in the Economics 

analysis (Section 3.13). Table 3.13-5 shows the revenues associated with the project and the mitigation 

activities, while Table 3.13-6 shows the improvement opportunities and possible funding sources. 

SOILS

Commenters raised concerns about the effectiveness of subsoiling, the Region 1 soil quality guidelines; 

failure to conduct field reviews; and guidelines pertaining to coarse woody debris. 

Information concerning subsoiling is included in Chapter 4, Response to Comments of the FEIS and

disclosed in the soils analysis, Section 3.5, as are the Region 1 soil quality guidelines and field reviews.
Record of Decision

Lower West Fork Project ROD - 25

Concerns raised about the effectiveness of soil mitigations in the compacted portion of Unit 1 prompted 

additional ID Team discussions and an alternative method for treating the area. The alternative method was 

incorporated into Alternatives 3 and 3–modified and will be implemented as part of my decision. 

WILDLIFE – ELK HABITAT EFFECTIVENESS AND THERMAL COVER

Concerns were raised about road management and how they were considered in the determination of elk 

habitat effectiveness. Also, concerns were raised about the proposed Bitterroot National Forest Plan 

(Forest Plan) amendments for elk habitat effectiveness and thermal cover. 

Both amendments were modified to clarify the intent and their application in the Lower West Fork 

Analysis Area. The elk habitat effectiveness and thermal cover analyses are also expanded and clarified in 

the FEIS. 

RECREATION AND ROADLESS

Concerns raised by commenters pertaining to unroaded and roadless areas dealt with the effects of the 

proposed treatments on unroaded areas. 

The effects of the proposed activities on roadless and unroaded areas are clarified and disclosed in Section 

3.12 of the FEIS. 

7.1 PUBLIC INVOLVEMENT

The concept for the Lower West Fork Project was introduced on a public field trip to review the similar 

Frasier Interface project in October of 2006. The feedback from this field trip was used to refine the 

proposed action for the Lower West Fork Project. Two additional field trips were held as the project 

developed in May 2007 and January 2008. 

A legal notice was published in the Ravalli Republic newspaper on March 7, 2007 (PF-Scoping-07-002). 

This notice provided details on the project and invited people to comment during the 30-day scoping 

period. News releases on the project proposal appeared in the Ravalli Republic on March 8, 2007. The 

Forest Service mailed a scoping letter, with four maps describing the proposed project and its background, 

to about 148 people, organizations, and agencies on March 7, 2007. They were invited to submit comments 

and questions on the project proposal by April 7, 2007. The Forest Service received 12 responses (PFScoping-001-009, 021, 023, 031). On March 10, 2007, the Forest Service established a Lower West Fork 

Project webpage providing public access to scoping letters, maps, and treatment examples used in the 

proposed action and alternatives. This website was updated as new information became available

(www.fs.fed.us/r1/bitterroot).

Preliminary ID Team analysis indicated that larger areas needed treatment to better apply current research 

and meet the project’s purpose and need of reducing crown fire risk on a landscape scale. In addition, the 

Rombo fire burned through several previously proposed units. Three of these units were proposed for 

prescribed fire, two for commercial harvest, and two for non-commercial thins. Only one of these units, a 

non-commercial thin unit would still benefit from treatment. The proposed action was expanded to treat 

additional areas within the analysis area boundary and a Notice of Intent was published on December 12, 

2007. The Notice of Intent opened another comment period that closed January 22, 2008. The Forest 

Service received 10 comments during this period. These comments in addition to the comments received in 

the initial comment period were used to identify issues and develop alternatives to the proposed action. 

The DEIS was completed and a Notice of Availability was published in the Federal Register on April 10, 

2009. The Notice of Availability opened the 45-day comment period that ended May 26, 2009. The Forest 

Service sent letters to 154 individuals, organizations, and agencies informing them that the DEIS was 

available as a document, compact disc, or on the Bitterroot National Forest web site. They also placed a 

legal advertisement in the Ravalli Republic, the newspaper of record, and distributed articles to the 

Missoulian, Missoulian on line, the Ravalli Republic, and the Bitterroot Star. The Forest Service received 
Record of Decision 

ROD - 26 Lower West Fork Project

six letters in response to these notifications and the comments in the letters were used to correct mistakes or 

clarify or amend the analysis. The ID Team added another alternative to evaluate the effects of stand 

treatments without the use of fire but did not carry that alternative through the analysis. The responses to 

all comments the Forest Service received are in Chapter 4. 

Public Meetings

Prior to the January 16, 2008 field trip, District Ranger Campbell briefed the Bitterroot Restoration 

Committee (BRC) on the project at a regularly scheduled meeting on December 18, 2007. The purpose and 

need for management and the BRC restoration principles were compared as part of the briefing. The BRC 

was also briefed on the project status at the regularly scheduled meeting on October 27, 2008.

7.1.1 HOW I CONSIDERED PUBLIC COMMENTS

Regardless of the source or form of the correspondence, or whether the comment was received during the 

official comment periods or afterwards, I considered each piece of correspondence. The public comment 

process provided many issues and concerns related to the project that were considered in the analysis (FEIS 

Chapter 4). I have reviewed these issues and concerns and I believe Alternative 3-Modified provides the 

best balance addressing public concerns and achieving the project purpose and need. 

8.1 FINDINGS RELATED TO OTHER LAWS AND REGULATIONS

To the best of my knowledge, my decision is consistent with all laws, regulations, and agency policy 

relevant to this project. The following discussion is not an all-inclusive listing, but provides information on 

topics raised by the public or other agencies.

8.1.1 NATIONAL FOREST MANAGEMENT ACT

The selected alternative is consistent with the National Forest Management Act (NFMA) requirements 

under 16 USC 1604 (g) (3) (E), which concerns even-aged management and clearcutting. The cutting of 

live trees to create an even-aged system is not proposed. 

1) No soil, slope, or other watershed conditions will be irreversibly damaged (FEIS pgs. 3.5-44, Appendix 

A). No system roads will be built during this project, so the project will not create any permanent 

impairment. Alternative 3-modified maintains organic matter, soil porosity, and topsoil through the use of 

Best Management Practices (BMPs), Soil and Water Conservation Practices (SWCPs), and mitigation

measures (FEIS pg. 3.5-44). Localized and limited detrimental soil disturbance will occur on landings, skid 

trails, temporary roads, or where soils are intensely heated, for example under logs or around roots. 

Detrimental soil disturbances will be managed according to Region 1 Soil Quality Guidelines to ensure soil 

productivity is maintained in activity areas. Compacted soils from terracing, historic logging activities, and 

re-used skid trails will be rehabilitated and trend soil productivity towards a net improvement (FEIS pgs. 

3.5-26 – 3.5-31)

2) The units will be fully stocked following the commercial thin and prescribed fire treatments. No 

regeneration harvest would occur therefore, there would is no need to restock stands withing 5 years (FEIS 

pg. 3.2-3).

3) Alternative 3-modified protects streams, stream banks, shorelines, lakes, wetlands, and other bodies of 

water from detrimental changes in water temperatures, blockages of water courses, and deposits of 

sediment through implementation of the Inland Native Fish Strategy standards and guidelines, 

programmatic agreements made with the U.S. Fish and Wildlife Service, BMPs, project design, and 

mitigations (FEIS pp. 3.7-8, 3.7-28, 3.7-34,2-20 – 2-21, Appendix A).

4) In Alternative 3-modified, the harvesting systems were selected based on site-specific resource 

requirements and not primarily to generate the greatest dollar return or the greatest unit output of timber 

(FEIS pg. 3.2-3). 
Record of Decision

Lower West Fork Project ROD - 27

SITE-SPECIFIC BITTERROOT NATIONAL FOREST PLAN AMENDMENT 

Implementation of Alternative 3-modified will require a site-specific amendment to the Bitterroot Forest 

Plan (1987) (FEIS p. 1-11 to 1-13) Appendix F. Therefore, my decision includes an amendment that will

modify the following Forest Plan standards specifically as they relate to the Lower West Fork decision:

Ø Elk habitat effectiveness

Ø Forest-wide thermal cover

Ø Coarse woody debris

Please see Appendix F of the FEIS for more detailed information pertaining to this amendment. Section 

1926.51 of the Forest Service Directives (www.fs.fed.us/emc/nfma/index5.html) gives guidance for 

determining what constitutes a “significant amendment” under NFMA. I have determined, based on this 

guidance, that this site-specific forest plan amendment is not significant because it will not significantly 

alter the long-term relationship between levels of multiple-use goods and services originally projected; and, 

it will not have an important effect on the entire land management plan or affect land and resources 

throughout a large portion of the planning area during the planning period. The amendment modifies 

standards and guidelines in the analysis area for the Lower West Fork project. Therefore, it is not a long 

term change in the plan. The public has been notified of this amendment throughout the NEPA process. 

FOREST PLAN CONSISTENCY

The Bitterroot National Forest Plan (Forest Plan) provides general management direction for the Forest, 

and establishes Forest-wide and management area standards and guidelines (USDA Forest Service 1987,

Chapter II). Management activities are to be consistent with the Forest Plan (16 USC 1604 (i)). 

I have evaluated the consistency of the alternatives with Forest Plan standards. Alternative 3-modified is 

consistent with the Forest Plan, meets Forest Plan standards, as amended, and will contribute toward 

reaching Forest Plan goals and objectives. Consistency with these standards can be found throughout the 

FEIS (pgs. 3.2-3 to 3.2-5 3.3-3 – 3.3-5, 3.3-22, 3.4-13, 3.5-45 – 3.5-46, 3.6-41 - 3.6-45, 3.7-34, 3.8-65 –

3.8-67, 3.9-11, 3.10-14 to 3.10-15, 3.11-5, 3.12-19). The Biological Evaluations and Biological 

Assessments confirm that this project will not impact the viability of sensitive, or threatened and 

endangered species. (FEIS pgs. 3.7-32 – 3.7-33, 3.8-68, 3.10-13 - 3.10-14.

8.1.2 NATIONAL ENVIRONMENTAL POLICY ACT 

NEPA requires Federal agencies to: (a) use a systematic interdisciplinary approach in planning and 

decision making; (b) consider the environmental impact of proposed actions; (c) identify adverse 

environmental effects which cannot be avoided should the proposal be implemented; (d) consider 

alternatives to the proposed action; (e) consider relationship between local short-term uses of the human 

environment and the maintenance and enhancement of long-term productivity; and (f) identify any 

irreversible and irretrievable commitments of resources which would be involved in the proposed action 

should it be implemented.

I find that the Lower West Fork analysis process and documentation is consistent with NEPA. The CEQ

provides NEPA guidance for government agencies, and interprets regulations on cumulative effects as; 

requiring analysis and a concise description of the identifiable present effects of past actions to the extent 

that they are relevant and useful in analyzing whether the reasonable foreseeable effects of agency proposal 

for action and its alternatives may have a continuing additive and significant relationship to those effects. 

The CEQ regulations do not require agencies to catalog and analyze all individual past actions. 

Information about past actions that may be available or obtained with reasonable effort does not mean that 

it is relevant and necessary to inform decisionmaking (CEQ 2005). However, I directed the Lower West 

Fork ID Team to catalog past harvest, road construction, and grazing activities and their effects, which is 

documented in Appendix B of the FEIS.
Record of Decision 

ROD - 28 Lower West Fork Project

8.1.3 CLEAN WATER ACT

The Lower West Fork project complies with the Clean Water Act (FEIS pgs. 3.6-42 to 3.6-43). Soil and 

water resources are protected through the application of design features and mitigation measures (FEIS pgs. 

2-17 to 2-24) and soil and water conservation practices listed in Appendix A of the FEIS. Though the West 

Fork of the Bitterroot River (West Fork River) is listed on the Montana 2008 impaired waters list, none of 

the tributaries in the Lower West Fork analysis area are listed. However, reducing sediment levels in these 

tributaries will decrease sediment levels in the West Fork River. The soil and water rehabilitation projects 

will reduce potential long-term sediment contributions to streams and contribute to the overall reduction of 

sediment in the West Fork River.

8.1.4 CLEAN AIR ACT

The basic framework for controlling air pollutants in the United States is the 1970 Clean Air Act, as 

amended in 1990 and 1999 (42 USC 7401 et seq.). The main air quality concern associated with this 

project is the amount and duration of particulate matter produced by prescribed burning. All prescribed 

burning will be implemented in full compliance with Montana Department of Environmental Quality air 

programs through cooperation with the Montana Idaho Airshed Group (FEIS p. 3.4-13). I have concluded 

that Alternative 3-modified meets the Clean Air Act and the Montana Clean Air Act (FEIS p. 3.4-8 to 3.4-

10).

8.1.5 ENDANGERED SPECIES ACT

The Bitterroot National Forest Fisheries Biologist, Wildlife Biologist, and Botanist evaluated the effects of 

the alternatives on threatened and endangered fish, wildlife, and plant, species, respectively (FEIS pgs. 3.7-

1 to 3.7-5, 3.7-10 to 3.7-15, 3.7-19 to 3.7-32, 3.8-42 to 3.8-44, 3.8-67, 3.10-1). The Fisheries Biologist 

prepared a Biological Assessment of bull trout (PF-FISH-002) and the U.S. Fish and Wildlife Service 

(USFWS) concurred with the Forest Service determination “that the proposed project is not likely to 

adversely affect bull trout, bull trout critical habitat, and proposed bull trout critical habitat.” (PF-FISH003). As there are no Threatened and Endangered wildlife or plant species known to occur on the 

Bitterroot National Forest, consultation with the USFWS was not required, and Biological Assessments

were not prepared (FEIS pgs. 3.8-1, 3.10-1). 

The USFWS no longer lists the Canada lynx as threatened or endangered on the Bitterroot NF (FEIS pgs. 

3.8-42). However, the project effects on Canada lynx habitat were evaluated as described in the NRLMD 

ROD (FEIS pg. 3.8-42) and the analysis showed there would be “No Effect” (FEIS pg. 3.8-44). 

Consultation with the USFWS is not required because Canada lynx are not listed as threatened on the 

Bitterroot NF and the determination was “No Effect.”

Forest Service resource specialists prepared Biological Evaluations or Biological Assessments for sensitive 

fish, wildlife, and plants and summarized the conclusions in the FEIS (FEIS pgs. 3.7-33, 3.8-67, 3.10-14, 

respectively). The conclusions were either “No Impact” or “May Impact Individuals or Habitat but not 

likely to contribute to a trend towards Federal listing or loss of viability to the population or species.” 

Alternative 3-modified would have effects similar to Alternative 3 because the soil and water rehabilitation 

projects would be the same and the timber harvest would be similar. The determinations of effect for 

threatened, endangered, and sensitive species were the same for Alternatives 2 and 3. Therefore, the 

determinations would be the same for Alternative 3-modified. 

8.1.6 ENVIRONMENTAL JUSTICE ACT

Executive Order 12898, issued in 1994, orders federal agencies to identify and address any adverse human 

health and environmental effects that disproportionately impact minority and low-income populations. 

Based on the composition of the affected communities and the cultural and economic factors, Alternative 3-
Record of Decision

Lower West Fork Project ROD - 29

modified will have no adverse effects on human health and safety or environmental effects on minority, 

low-income, or any other segments of the population (FEIS pg. 3.13-10).

Alternative 3-modified provides the option to treat potential new invasive plant populations with 

herbicides. The criteria for determining whether to use herbicides, which herbicides to use, and how to 

apply them will be the same as described in Alternative 2. The potential exposure to herbicides under 

Alternative 2 were determined to be very low (FEIS pg. 3.15-5) and would not disproportionately affect 

minorities or low income populations. Herbicide exposure would be less likely under Alternative 3-

modified because soil disturbance would occur on 758 fewer acres. Though more roads would be 

decommissioned and stored under Alternative 3-modified, it would increase the area of potential 

disturbance to 1,791 acres, which is less than the 2,549 acres of potential disturbance in Alternative 2.

8.1.7 MIGRATORY BIRD TREATY ACT

The design features and mitigation measures in Alternative 3-modified provide adequate conservation 

measures for migratory birds. Overall, impacts on forest land birds are expected to be minimal and are not 

expected to affect species viability (FEIS pg. 3.8-66).

8.1.8 NATIONAL HISTORIC PRESERVATION ACT

Alternative 3-modified would not affect any cultural resources. Recognizing the potential exists to 

encounter and disturb unidentified sites during project activity, mitigation practices require halting 

activities and notifying the Forest Archaeologist, if cultural resources are encountered during project 

implementation. Formal consultation has been completed with the Confederated Salish and Kootenai

Tribes and the State Historic Preservation Office in accordance with the Memorandum of Understanding

(PF-HERT-002). Heritage and Tribal interests are regulated by federal laws that direct and guide the Forest 

Service in identifying, evaluating and protecting cultural resources. Alternative 3-modified will comply 

with these federal laws because both Alternative 2 and Alternative 3 comply (FEIS pg. 3.11-5) and 

Alternative 3-modified is within the parameters of these two alternatives.

8.1.9 ENVIRONMENTALLY PREFERRED ALTERNATIVE

The Council on Environmental Quality defines the environmentally preferred alternative as “the alternative 

that will promote the national environmental policy as expressed in NEPA’s Section 101. Ordinarily, this 

means the alternative that causes the least damage to the biological and physical environment; it also means 

the alternative which best protects, preserves, and enhances historic, cultural, and natural resources.” This 

definition could be generalized to mean the alternative that best balances negative impacts with benefits.

Alternative 1 (No Action) would impact the biological and physical environment the least in the short-term 

because no ground-disturbing activities would occur. However this alternative does little to improve stand 

growing conditions and forest density will increase. Over time, stand resilience to environmental stressors 

would decline and the forest will increasingly become susceptible insects, disease, and fire. In addition, no 

road decommissioning or storage and associated culvert removal would occur and current trends in 

sediment contributions to associated streams would continue. This alternative would not contribute to the 

sediment reduction target identified in the Water Quality Restoration Plan and Total Maximum Daily 

Loads for the Bitterroot Headwaters Planning Area

Alternative 3-modified offers the best balance between meeting the purpose and need for the project and 

minimizing long-term environmental effects. The units on the west side of the West Fork River are treated 

under Alternative 3-modified, which links fuel treatments in three previous decisions. These treatments

provide a buffer across the landscape between the Selway-Bitterroot Wilderness and private land 

boundaries, which would likely increase fire management options. Alternative 3-modified retains the 

prescribed fire units on the east side of the River, which combined with past treatments and fires, will 

(DEQ 2005). Fish habitat would continue to be 

fragmented at the seven fish barrier culverts. Soil rehabilitation would continue at the normal rate and 

would not be expedited through subsoiling or slash decomposition. 
Record of Decision 

ROD - 30 Lower West Fork Project

provide some fire management options while not creating additional disturbance in drainages recovering 

from the effects of the Rombo fire. By not commercially thinning the units on the east side of the river at 

this time, log truck traffic will not be on roads next to streams that are prone to increased sedimentation 

from the Rombo fire. I conclude that the commercial thin treatments on the east side of the West Fork 

River are not as critical to enhancing fire management options. Past fire activity and harvest treatments and 

the proposed prescribed fire and terrace treatments provide adequate opportunities to manage fire and 

protect resources in the WUI. 

Retaining the option to combat new weed infestations using herbicides is an important feature analyzed in 

Alternative 2 that needs to be retained in Alternative 3-modified. These drier ecotypes are prone to weed 

infestations and weed seed sources typically are adjacent to treatment areas. Though preventive and 

mechanical methods of eradication are preferable, not all weed species can be treated in this manner.

Alternative 3-modified also restores the most soil and watershed conditions. The treatment of the portion 

of Unit 1 with high levels of soil disturbance has the potential to accelerate the recovery of soil conditions. 

Terrace units will be treated to improve stand growing conditions and enhance soil rehabilitation rates. 

This Alternative also decommissions or stores the most roads and removes the most culverts from roads not 

needed for forest management, which in turn reduces the most sedimentation and restores fish habitat 

connectivity. 

Considering these factors, I conclude that Alternative 3-modified is the environmentally preferred 

alternative. 

8.1.10 PERMITS REQUIRED

Removing or replacing culverts within an active stream channel requires a 124 permit from the Montana 

Department of Fish, Wildlife, and Parks. In certain instances, a 404 permit from the Army Corps of 

Engineers or 318 permit from Montana Department of Environmental Quality, may also be required. The 

applicable permits must be obtained prior to conducting the work. The permits sometimes contain 

additional site-specific mitigations to minimize damage to the aquatic ecosystem. Appropriated dollars 

from the Forest Services annual budget is also required for implementation of the culvert work. No other 

permits, licenses, grants, or authorizations are needed to implement the decision. 

9.1 APPEAL PROVISIONS

This decision is subject to appeal pursuant to 36 CFR 215.11. A written appeal must be submitted within 

45 days following the publication date of the legal notice of this decision in the Ravalli Republic, the 

newspaper of record in Hamilton, Montana. It is the responsibility of the appellant to ensure their appeal is 

received in a timely manner. The publication date of the legal notice of the decision in the newspaper of 

record is the exclusive means for calculating the time to file an appeal. Appellants should not rely on date 

or timeframe information provided by any other source. Appeals must be submitted to:

USDA Forest Service, Northern Region 

ATTN: Appeal Deciding Officer 

P.O. Box 7669 

Missoula, MT 59807

Or USDA Forest Service, Northern Region

ATTN: Appeal Deciding Officer 

200 East Broadway 

Missoula, MT 59802

(Office hours are Monday through Friday from 7:30 a.m. to 4:00 p.m., except holidays.)

Electronic appeals must be submitted to: appeals-northern-regional-office@fs.fed.us

Faxed appeals must be submitted to: Fax: (406) 329-3411

In electronic appeals, the subject line should contain the name of the project being appealed. An automated 

response will confirm your electronic appeal has been received. Electronic appeals must be submitted in 

MS Word, Word Perfect, or Rich Text Format (RTF).

Record of Decision 

ROD - 32 Lower West Fork Project

LIST OF REFERENCES CITED IN THIS DECISION

The following references were cited in this Record of Decision. Additional literature is cited in the Final 

Environmental Impact Statement.

Arno, S.F., Carl Fiedler. 2005. Mimicking Nature’s Fire: Restoring Fire-Prone Forests in the West. pp 154-

159. Island Press, Washington, D.C., USA [0412]

Cram, D.S., T.T. Baker, and J.C. Boren. 2006. Wildland Fire Effects in Silviculturally Treated vs. 

Untreated Stands of New Mexico and Arizona. Paper RMRS-RP-55. USDA Forest Service, Rocky 

Mountain Research Station, Fort Collins, Colorado, USA. [1182]

Dept. of Natural Resource Conservation, Bitter Root Resource Conservation & Development Area, Inc., 

USDA Forest Service, et al. 2006, updated 2010.

http://www.bitterrootfireplan.info/pdf/CWPP_20091215.pdf

Finney, M. A., C.W. McHugh, and I.C. Grenfell. 2005. Stand and landscape level effects of prescribed 

burning on two Arizona wildfires. Canadian Journal of Forest Research 35: 1714-1722 [0427]

Graham, Russell T.; McCaffrey, S.; Jain, T. B. (tech. eds.) 2004. Science basis for changing forest structure 

to modify wildfire behavior and severity. Gen. Tech. Rep. RMRS-GTR-120. Fort Collins, CO: U.S. 

Department of Agriculture, Forest Service, Rocky Mountain Research Station. 43 p. [0130]

Hessburg, P. F., Mitchell, R. G., Filip, G. M. 1994. Historical and current roles of insects and pathogens in 

eastern Oregon and Washington forested landscapes. Gen. Tech. Rep. PNW-GTR-327. Portland, OR: 

USDA Forest Service, Pacific Northwest Research Station. 72 p. [0185]

Montana Department of Environmental Quality (MDEQ). 2008. Montana Numeric Water Quality 

Standards http://www.deq.state.mt.us/wqinfo/standards/pdf/CompiledDEQ7.pdf [1191]

Schmidt, D.A., A.H. Taylor, and C.N. Skinner. 2008. The Influence of Fuels Treatment and Landscape 

Arrangement on Simulated Fire Behavior, Southern Cascade Range, California. Forest Ecology and 

Management 255:3170-3184 [1183]

Skinner, Carl N., Martin W. Ritchie, Todd Hamilton, and Julie Symons. 2004. Effects of Thinning and 

Prescribed Fire on Wildlife Severity. pp 80-91. IN S. Cooper, editor. Proceedings 25th Annual Forest 

Vegetation Management Conference, January 20-22, 2004, Redding, CA. University of California 

Cooperative Forestry Extension, Redding, CA USA [0372]

Stephens, Scott L., Jason J. Moghaddas, carl Edminster, Carl E. Fiedler, Sally Haase, Michael Harrington, 

Jon E. Keeley, Eric E. Knapp, James D. McIver, Kerry Metlen, Carl N. Skinner, and Andrew 

Youngblood. 2009. Fire Treatment Effects on vegetation structure, Fuels, and Potential fire Severity in 

Western U.S. Forests. Ecological Applications 19(2):305-320 [1184]

USDA, Forest Service. 1987. Forest Plan, Bitterroot National Forest. USDA Forest Service, Northern 

Region. Hamilton MT, September, 1987. [0120]

USDA Forest Service. 2004. Forest Plan Monitoring and Evaluation Report, Fiscal Year 2004, Bitterroot 

National Forest, Hamilton, MT. [0325]
Appendix A – Best Management Practices

Lower West Fork Project ROD A-1

APPENDIX A

BEST MANAGEMENT PRACTICES

BITTERROOT NATIONAL FOREST

2.3 MITIGATION MEASURES AND PROJECT DESIGN

The Forest Service designs projects and specifies practices that prevent or mitigate adverse effects of 

project activities. These design features and management practices come from direction in the Forest Plan, 

and Forest Service manuals and handbooks. The design features and mitigation practices specified in the 

alternatives are outlined in Tables A-1 and A-2.

Table A-1: Mitigation Practices and Design Features in Alternatives 2 and 3 of the Lower West Fork 

Project 

Objective Mitigation Practice or Design Feature

Soils

Minimize soil erosion and 

compaction

Activities will comply with Best Management Practices (BMPs) to minimize 

effects to soil resources. BMPs are listed in Appendix A. Complete descriptions 

are available in the Project File.

Reduce soil erosion, prevent 

sedimentation into streams, and 

prevent the spread of noxious 

weeds

Disturbed sites will be evaluated by timber sale administrators (TSAs) and/or 

resource specialists to determine erosion control and revegetation needs. Soil 

disturbances associated with landings, roadside ditches, temporary roads, or other 

areas would be rehabilitated as soon as possible by re-contouring, shallow 

ripping (6-12 inches) as needed, seeding, fertilizing, planting of shrubs, and 

covering with mulch or slash.

Minimize soil compaction Skid trails will be designated and historic skid trails will be used to the extent 

feasible in units yarded by ground-based systems.

Winter ground-based yarding is required in Unit 1 below FS road 363 

(approximately 65 acres) under Alternative 2. The winter yarding will be 

required to follow standard winter timber operating procedures. Commercial 

thinning operations will be required to limb and leave tops in this area. Woody 

debris levels should range from 15 to 20 tons/acre on the ground following 

thinning to enhance natural soil rehabilitation The woody debris will be a mix of 

fine and coarse wood.

Summer ground-based yarding will occur when soils are dry (soil moisture is 

near or below the permanent wilting point).

Winter ground-based yarding:

The snow depth, distribution, and air temperature conditions must be such that 

ground-based operations maintain the following combination of snow depth and 

frozen soil conditions under

Depth of compacted (by equipment) 

snow under wheels or track/tread

the wheels or tracks/treads of equipment at all 

times. (* see below).

Minimum thickness of solidly frozen 

soil needed below compacted snow 

layer

10 or more inches 0 inches

7 to 10 inches 1 inch

4 to 7 inches 2 inches

less than 4 inches 4 inches

*Pre-trailing. Pre-trailing selected skid trails a day or so prior to skidding or 

other heavy trail use is a way to achieve this objective. If average, pre-compacted 
Appendix A – Best Management Practices

A-2 Lower West Fork Project ROD 

Objective Mitigation Practice or Design Feature

snow depth along the proposed trail is more than 15 inches, pre-trailing can be 

done whether or not the soil is frozen. If pre-compacted snow depth is 8 to15 

inches, pre-trailing should be done only if the soil is solidly frozen in the top one 

inch or more. Otherwise, pre-trailing should be delayed until more snow falls to 

accumulate another 8 inches or more. To further aid soil protection, pre-trailing 

should be done using an “easy-does-it” approach, including slow ground speeds 

and steady movements. Avoid spinning tires and bouncing equipment on trails as 

much as possible. Adequate pre-trailing air temperatures are generally in the low 

20s  ̊Fahrenheit or lower. For more information about pre-trailing conditions, 

consult with the Forest soil scientist.

Subsoiling will occur on all skid trails used for yarding in the proposed summer 

ground-based units. If winter ground-based yarding is used in units 3 and 12, 

subsoiling of historic skid trails will be required in order to create a net 

improvement in soil productivity in these units. A SGR or excavator subsoiling 

implement that achieves desired results will be used; proper application of 

subsoiling does not mix soil horizons and will cause minimal disturbance to 

surface soil/litter layers. Subsoiling will also occur on all skid trails in skyline 

units where summer, tractor swing is required. When available, slash will be 

placed on the decompacted skid trails by the SGR.

Reduce detrimental soil 

disturbance (DSD) 

Feller/buncher equipment may be used on skyline units pending the results of 

studies conducted in the Trapper Bunkhouse project area. If DSD exceeds 2%, 

then feller/bunchers will NOT be used on skyline units in the Lower West Fork 

Project area. These units will be harvested using conventional felling and skyline 

yarding methods.

Rehabilitation activities on new temporary roads and Tracked line machine trails 

will include recontouring, slashing, and seeding. 

Historic roads used for hauling will be stabilized by removing drainage 

structures; ripping, seeding, and fertilizing the road bed; and closing the entrance 

to these roads. 

Reduce DSD and prevent the 

spread of noxious weeds

Hand pile sizes inside units will average 6-8 feet in diameter so localized areas of 

soil disturbance will be less than about 50 square feet. This does not pertain to 

slash created on landings during yarding operations.

Burning of piles should occur during wet conditions when the duff is moist. The 

entire duff profile should be moist to the touch in the pile locations.

Prevent the creation of new areas 

of DSD 

Where feasible, pile and burn slash where detrimental soil disturbance already 

exists, such as on old log landings, skid trails, and roads associated with the past 

harvest units. This practice will prevent the creation of new areas of detrimental 

soil disturbance.

Maintain 70% ground cover

The soil scientist will be consulted prior to burning to ensure soil conditions are 

acceptable for burning. Prescribed burning in terrace and non-terraced noncommercial thin units will only be completed through piling and burning on a 

case by case basis, pending field review by the soil scientist. 

At least 70 percent ground cover is necessary to prevent detrimental accelerated 

erosion and loss in soil productivity after treatments are completed. Ground 

cover includes duff, organic soil horizons, vegetation basal area, fine woody 

debris, coarse woody debris (CWD), and surface coarse fragments. In those 

cases where ground cover is less than 70 percent prior to burning, fuel 

consumption and ground cover loss should not exceed 15 percent. Prescribe fire 

prescriptions will be designed to meet these soil protection requirements.
Appendix A – Best Management Practices

Lower West Fork Project ROD A-3

Objective Mitigation Practice or Design Feature

Maintain soil productivity

CWD (material greater than 3 inches in diameter) left on site will include leave 

trees both standing and down, and broken limbs and tops created by timber 

harvest. Amounts will be within ranges identified in Section 1.7 D, with the 

exception of unit 1 and terraced units. 

In unit 1, fine and coarse woody debris from logging slash will be spread 

uniformly across the compacted portions of the ground-based unit (below FS 

road 363) at a rate of 15 to 20 tons/acre to increase organic matter for soil 

rehabilitation. Under burning will not be completed in this 65 acre area of unit 1. 

Mechanical thinning operations in terrace units will ensure adequate woody 

debris (fine and coarse wood) is left for soil rehabilitation on the terrace benches. 

This may require some limbing and leaving tops to ensure an adequate amount of 

woody debris is available for soil rehabilitation on the benches. An organic 

fertilizer, woody debris (rate of 10 to 15 tons/acre), or combination of both will 

be applied following subsoiling or ripping on the terrace benches to improve soil 

organic concentrations, nutrient cycling, and microbial populations. Risers in 

between benches should meet CWD standards described in Section 1.7 D. Under 

burning will not be completed on the terrace units. If fuel reduction is required 

after mechanical harvest and soil rehabilitation activities, piling and burning will 

be completed on a case by case basis pending field review by the soil scientist. 

Woody debris levels should be 10 to 15 tons/acre throughout the non-terraced 

plantations following all treatments including potential piling and burning.

The silvicultural prescriptions will be designed to account for future large CWD 

(>15 inches diameter) recruitment that will meet acceptable levels in stands 

where CWD is less than minimum levels before treatment. CWD will be left in 

these stands to the extent feasible to meet minimum requirements that do not 

pose a fuels hazard. High amounts of small CWD (3-15 inches diameter) may 

present wildfire risks. 

CWD will generally be evenly distributed on each acre, unless otherwise agreed 

to by the Contracting Officer or their designee. 

Prescribed burning operations will maintain CWD levels where existing CWD is 

less than required minimum levels. Burning should attempt to increase CWD 

recruitment where possible. 

Wood larger than 15 inches in diameter will not be intentionally ignited during 

hand lighting. It is understood that once hand crews light the fire, fire may burn 

into and combust some large CWD. Coarse woody debris will meet standards 

stated in Section 1.7 D, with the exception of terrace units and unit 1.

Allow time for nutrients to leach 

from slash prior to burning

The slash will be left in all commercial thin units through one winter after cutting 

to allow for initial decomposition and nutrient leaching.

Watershed and Fisheries

Ensure that water-related 

beneficial uses are protected and 

that State water quality standards 

are met

Trees will not be harvested from Riparian Habitat Conservation Areas (RHCAs). 

If trees felled outside of the RHCAs land or roll into the RHCAs, their boles may 

be removed, but the tops and limbs will be left behind. The RHCAs are:

within 300 feet of fish-bearing streams

within 150 feet of permanently flowing, non-fish bearing streams

within 100 feet of seasonally flowing or intermittent streams

within 150 feet of ponds, lakes or wetlands > 1 acre in area

within 50 feet of ponds, lakes or wetlands < 1 acre in area

within 50 feet of landslide prone areas (USDA Forest Service 1995).

RHCA boundaries will be designated and marked on the ground in consultation 

with the Fisheries Biologist. 
Appendix A – Best Management Practices

A-4 Lower West Fork Project ROD 

Objective Mitigation Practice or Design Feature

Ensure that water-related 

beneficial uses are protected cont.

In RHCAs, trees can be felled when they pose a safety risk. Felled hazard trees 

will be left on-site (INFISH standard RA-2), unless their removal is deemed 

necessary for safety reasons by the TSA. 

Log landings, temporary roads, and tracked line machine trails will not be located 

in the RHCAs.

Generally, no fuel storage, mixing of fuels, or refueling equipment will occur in 

the RHCAs. If there are no other alternative areas, refueling sites in RHCAs may 

be used, but they must be approved by the Fisheries Biologist and have an 

approved spill containment plan prior to their use. Small pumps (for example, 

Mark III) and chainsaws can be refueled within the RHCA as long as proper spill 

containment actions are implemented (USDA Forest Service1995).

Protect the streamside 

management zone (SMZ) All activities will comply with the Montana Streamside Management Zone Act.

Ground-based equipment will be prohibited from entering SMZs without the 

appropriate variance from Montana DNRC. Boundaries of RHCAs will be 

marked to exclude equipment operation.

Best Management Practices will be applied and monitored during the 

administration of the contract. Applicable BMPs are in the Project File and 

summarized in Appendix A.

Protect Forest roads used during 

log hauling operations

The TSA and/or resource specialists will monitor road conditions to ensure they 

do not contribute sediment to streams. Road maintenance activities (including 

snowplowing and dust abatement) will follow the requirements specified in the 

USFSW1 Programmatic Biological Assessment for road maintenance (1999). 

Prevent sediment entering streams 

from encroached segments of haul 

roads

On the encroached haul road segments (Pierce Creek #363, Lavene Creek #5630, 

and Piquett Creek #49 Roads) –

Straw bale check dams will be installed below the outlets of all ditch relief 

culverts, in the road ditches that empty into streams, and below road drainage 

features such as drive-thru dips that lack adequate riparian filter distance. The 

check dams will be installed prior to winter hauling, and maintained during all 

periods of winter hauling. 

Outlets of all ditch relief pipes will be kept free of snow blockage during winter 

haul.

Snow berm drainage holes will be designated prior to winter haul, and kept open 

throughout the duration of winter hauling.

Roads proposed for long-term 

storage or culvert 

removal/restoration

Seed, fertilize and slash roads after decompaction and/or recontouring, mulch to 

the extent feasible. Seed mix will be as prescribed by the Forest Botanist. Mulch 

is required on sites located within sediment contributing distance of streams 

(about 300 feet). Where culverts with flowing water are removed, a strawbale 

check dam will be installed below the outlet prior to removing the culvert. 

All units with manual thinning Trees will not be manually thinned and slash piles will not be created within 50 

feet of streams and wetlands. 

Protect RHCAs during prescribed 

burning

Helicopter ignition will not occur in the RHCAs. Hand ignition can occur in all 

of the RHCAs except wetlands. Fire will be allowed to back into or burn through 

the RHCAs. 

In Units 32, 33, and 60A, no ignition (hand or helicopter) will occur within 300 

feet of Pierce Creek and Lavene Creek.

Generally, hand fireline will not be dug in the RHCAs. If needed, hand fireline 

can be dug in the RHCAs, but it must 1) avoid wetlands, 2) be constructed with 

proper drainage structures, and 3) be recontoured and covered with slash upon 

completion of the burn. Machine fireline is prohibited in all RHCAs. 

If drafting from streams occurs, intake hoses will be fitted with a screen mesh 

equal to or smaller than 3/32 inches. Intake hoses will be placed in low velocity 

portions of the stream channel (< 0.4 feet/second of flow).
Appendix A – Best Management Practices

Lower West Fork Project ROD A-5

Objective Mitigation Practice or Design Feature

Protect aquatic resources and 

ground water during herbicide 

application

High effectiveness

Application standards.

(W1) Mixing and loading of tanks will occur more than 300 feet from live water 

where possible. No mixing will occur within 100 feet of live water.

(A1) Herbicides will not be used to control weeds within a 100-foot radius of any 

potable water spring development or diversion within the project area.

Protect aquatic resources during 

herbicide applications

High effectiveness.

Avoids potentially harmful 

exposure

(A2) No ester formulations of herbicides will be used (i.e., 2,4-D ester, triclopyrBEE), due to relatively high fish toxicity.

Protect aquatic resources and 

ground water during herbicide 

applications

High effectiveness.

Practical experience.

(A3) Use of herbicides and surfactants within 100 feet of surface water will 

adhere to distances and conditions outlined in Table 3.7-4, Herbicide Use 

Restrictions in RHCAs (Chapter 3 section 3.7 Fisheries) 

(A4) In areas adjacent to known stream reaches where bull trout spawn (Boulder 

Creek and Piquett Creek), no herbicides would be used within 15 feet of the 

stream, no picloram within 100 feet, and no application after July 15.

Timber Management

Prevent pine engraver (Ips spp.) 

population increases

All thinning in units with ponderosa pine and lodgepole pine must be performed 

between the months of July 1 thru December 31. Slash must be properly disposed 

of, i.e., piled and burned or lopped and scattered. Where limbs and tops exceed 

three inches in diameter, they need to be bucked in four-foot lengths and 

scattered to allow time for larger boles to dry out and not become Ips beetle host 

sites the following year. 

Prevent the spread of annosus root 

disease

Apply borate to freshly cut ponderosa pine stumps greater than 12 inches in 

diameter inside bark.

Protect TES Plant Populations and their Habitat/Promote Healthy Native Plant Communities

Avoid dwarf onion populations 

during harvest operations in units 

3, 18, 41, 64, 68, 69, 70, 73, 74

Dwarf onion (Allium parvum) populations will be located by GPS and marked on 

sale area maps for avoidance during skidding and slash piling.

Avoid Rocky Mountain paintbrush 

populations during harvest 

operations in units 6 and 70

Rocky Mountain paintbrush (Castilleja covilleana) populations will be located 

by GPS and marked on sale area maps for avoidance during skidding and slash 

piling.

Avoid Lemhi penstemon 

populations in units 22 and 66

Lemhi penstemon (Penstemon lemhiensis) populations will be located by GPS 

and marked on sale area maps for avoidance during skidding and slash piling.

To reduce the risk of weed spread 

All Units

Clean equipment prior to moving into the project area, minimize soil disturbance, 

and revegetate disturbed soil where native plant recovery may be delayed 

(consult Forest Botanist for specific recommendations) as outlined in FSM 2000, 

Zero Code 2080 – Noxious Weed Management (R1 Supplement No. 2000-2001-

1). 

Landings, Temp Roads, TLM 

paths

Botanist will evaluate temporary roads, TLM paths, and landing locations that 

have not previously been surveyed for sensitive plants. Sensitive plant locations 

would be avoided or an alternate site would be used.

Herbicide Treatments

(Alternative 2)

Lemhi penstemon plants along NFS roads 13423 and 5723 will be avoided 

during roadside spraying. The Forest Botanist will be contacted prior to off-road 

herbicide applications to ensure that sensitive plants will be avoided. Sensitive 

plants are known to occur in units 3, 18, 22, 41, 64, 66, 68, 69, 70, 73, and 74. 

GPS locations will be made available to applicators so plants can be avoided. 

Prevent weed spread along road 

corridors

Treat haul roads and access roads with herbicides prior to implementing harvest 

and/or burning activities. 

Promote successful revegetation Treat temporary roads, TLM trails and landings with herbicides after harvest 

activities are completed and prior to revegetating. 
Appendix A – Best Management Practices

A-6 Lower West Fork Project ROD 

Objective Mitigation Practice or Design Feature

Protect sensitive plants from 

herbicides

Protect sensitive plants from 

herbicides (cont.)

Moderate to High Effectiveness

(SP1) Consult with district/forest botanist each year for updates to speciesspecific protection measures, before any site applications begin.

(SP2) All treatment sites will be evaluated for sensitive plant habitat suitability. 

Highly suitable habitat will be surveyed as necessary prior to treatment.

(SP3) Provide the weed crew with maps of all known sensitive plant locations so 

that these sites can be identified and protected.

(SP4) Train the weed crew to identify sensitive plants so that new sites can be 

identified and protected.

(SP5) The Forest Botanist will provide site-specific treatment guidelines for 

weed infestations within or adjacent to known sensitive plant populations.

(SP6) No spraying with vehicle-based spraying devices will be done within 50 

feet of any known sensitive plant occurrence.

(SP7) No chemical spraying will be done within 25 feet of any known sensitive 

plant occurrence, only mechanical treatment would be used.

Herbicide Use (Alternative 2)

Control Application Rates; 

Moderate effectiveness

Monitor –equipment for wear

(H1) Operators shall calibrate spray equipment at regular intervals 

(approximately after every 80 to 160 hours of use) to ensure proper rates of 

herbicide applications using standard methods.

Ensure responsible application of 

herbicide; Moderate effectiveness 

Monitor –Daily Pesticide 

Application Record or similar 

database.

(H2) Herbicides will be used in accordance with label instructions and 

restrictions. Application will be done or supervised by licensed applicators.

High effectiveness (Professional 

experience)

(H3) Herbicide applicators shall carry spill containment equipment, as described 

and in the Herbicide Emergency Spill Plan, and be familiar with and carry an 

Herbicide Emergency Spill Plan. A spill cleanup kit will be available at 

temporary storage sites and with all transportations (vehicles, raft, plane, mules) 

carrying herbicides.

Prevent spillage in rafts that may 

come into contact with humans or 

may directly enter surface waters.

High Effectiveness, Practical 

experience.

(H4) Equipment used for transportation, storage, or application of herbicides 

shall be maintained in leak proof condition. 

Prevent contact with open water. 

High effectiveness. Logic.

(H5) Chemicals will not be used over live water (streams, ponds, springs, etc.), 

including water standing or running in ditch lines.

Dry roadside ditches that lead to intermittent and perennial streams will not be 

sprayed with any herbicide containing picloram.

Avoid impact to sensitive plants 

and non-target aquatic species.

High effectiveness Professional 

experience.

(H6) Procedures for mixing, loading, and disposal of herbicides and a spill plan 

will be followed. All herbicide storage, mixing, and post-application equipment 

cleaning will be completed outside of RHCAs. If no other alternative is 

available, mixing and loading operations must take place in an area where an 

accidental spill would not contaminate a stream or body of water before it could 

be contained. Particular attention will be given to avoiding mixing, loading, or 

cleaning within 100 feet of live water. These procedures are referenced in 

Appendix A and B of the Draft Selway-Bitterroot Invasives EIS (2008). Drafting 

equipment used for filling herbicide spray tanks will be equipped with 

appropriate back-siphoning prevention devices.

Assure product safety.

High effectiveness.

EPA Studies.

(H8) Additional herbicides may be considered for use within the project area in 

the future. Only EPA registered herbicides having a completed Human Health 

and Ecological Risk Assessment Final Report will be considered for use. 

Additional consultation regarding ESA-listed species will occur for the use of 

any new herbicide not included in this Record of Decision.
Appendix A – Best Management Practices

Lower West Fork Project ROD A-7

Objective Mitigation Practice or Design Feature

Inform public and reduce 

exposure; High effectiveness 

(Logical – prevent exposure)

(H9) Roads receiving treatment will be posted with the date of treatment and 

chemical applied. 

Provide for annual, pre-application 

oversight.

High effectiveness.

Coordination.

(H10) The Annual Plan of Operations for herbicide application will be reviewed 

by an interdisciplinary team that includes, at a minimum, hydrology and or 

fisheries biology, botany, and wildlife biology skills. The review will take place 

prior to implementation to ensure the protection of native flora and fauna and to 

ensure that herbicide thresholds, as described in the Fisheries section of Chapter 

3, are not exceeded

Prevent contact with open water. 

High effectiveness. Logic.

(H11) No herbicide spraying will occur during rain or when rain is imminent. 

Dry roadside ditches that lead to intermittent and perennial streams will not be 

sprayed with any herbicide containing picloram.

Protect Aquatic Resources; High 

effectiveness

Prior testing.

(H12) Use of surfactants will occur as previously described, using only the 

surfactants listed and according to the allowable distances to live water displayed 

in Table 2-9 below.

Safe handling of herbicide; High 

effectiveness (Logical – visible)

(H13) Water-soluble colorants, such as Hi-Light® blue dye, will be used within 

100 feet of water and in other situations as needed to enable applicators and 

inspectors to better see where herbicides have been applied.

General Safety; High 

Effectiveness; Logical – high 

visibility

Traffic control and signing during weed-treatment operations will be used as 

necessary to ensure safety of the public and workers.

Protect Cultural Resource sites; 

High effectiveness (Logical –

avoids impact to area)

(C1) Mechanical/cultural treatments that disturb soil, will not be used on any 

known historical or archaeological site without proper clearances by a Forest 

Heritage Resource Specialist.

Wildlife

Retain old growth habitat 

characteristics in units that contain 

old growth habitat (units 4, 8, 9, 

15, 33, 60A, 61A, 70, 71)

The Silviculturist and Wildlife Biologist will monitor stand marking and timber 

harvest to ensure the stands meet Green et al. (1995, addednum 2005) old growth 

criteria. 

Snags Retain all snags unless designated “danger” trees (29CFR 1910.266(h)(1)(vi,vii).

Retain downed, woody debris

Fire Type Group Coarse Woody Debris

 2, 4 5-10 tons/acre

 6 10-20 tons/acre

 7, 8, 9 8-24 tons/acre

Protect amphibians and herptiles

High effectiveness with training 

and diligence of applicator.

Avoids potentially harmful 

exposure.

(W1) When ground application of authorized herbicides is necessary within 50 

feet of a water body, wetland, or river beach, applicators will survey the 

treatment area at time of application to determine potential presence of 

amphibians and aquatic associated herptiles.

The broadcast spray application method will not be used if adult amphibians or 

aquatic associated herptiles are identified.

The extent of species population distribution in the treatment area will be 

reported to the district amphibian specialist (Fisheries or Wildlife Biologist) as 

soon as possible. Hand pulling or wick application will be used or treatment will 

be deferred on advice of the amphibian specialist if treatment is not possible 

without directly spraying individuals.

If tadpoles or amphibian metamorphs are identified, the location will be reported 

to the amphibian specialist and weed coordinator as soon as possible, and 

application of herbicides will be delayed until metamorphs disperse.

Reduce potential for incidental 

contact of spray compounds with 

non-target species of concern.

(W2) Avoid directly spraying any terrestrial organism other than invasive plant 

species, including snakes, lizards, salamanders, small mammals, ground nesting 

birds, and insect concentrations such as ladybug swarms.
Appendix A – Best Management Practices

A-8 Lower West Fork Project ROD 

Objective Mitigation Practice or Design Feature

Moderate effectiveness due to 

tendency for some species to hide 

under rocks and debris. 

Practical experience.

If treatment is not possible without directly spraying individuals, then hand 

pulling or wick application will be employed.

Minimize impact to nesting 

eagles; High effectiveness (MT 

Bald Eagle Working Group. 1994. 

page 24)

(W3) Activities associated with weed control will avoid areas within 400 meters 

of active bald eagle or peregrine falcon nest sites unless the Wildlife Biologist 

provides further direction.

Minimize human effects on 

wildlife.

High effectiveness.

Practical experience.

(W4) Food, garbage, and human waste associated with project implementation 

work crews will be properly managed so as not to attract or habituate wildlife.

Crew camps will be located to avoid disturbance to wildlife in reproductive sites 

during active reproductive periods, including calving and lambing areas, raptor 

nesting and carnivore den sites.

Protect Bog Lemmings.

Avoids potentially harmful 

exposure.

High Effectiveness based on 

research

W5) Chemical application is prohibited within 300 feet of all sites where 

northern bog lemmings are known to occur, as well as peatland sites not yet 

surveyed for northern bog lemmings, pending review and approval by the Forest 

Wildlife Biologist.

Table A-2: Adjuvants (Surfactants) Proposed for Use and Allowable Distance to Live Water 

Surfactant

Distance to Live Water Use Allowed

0 – 15’ >15 – 50’ >50 –

100’ > 100’

Agri-Dex, and Super Spread MSO Yes Yes Yes Yes

Cide Kick II No Yes Yes Yes

R-11, Activator 90, X-77, Latron AG-98, Pro-Spreader Activator, 

Cide-Kick, LI-700, Spreader 90, Syl-tac, Cygnet Plus, Sylgard 

309, Freeway, Silwet L-77, Kinectic, and Inlet

No No Yes Yes

R-900, R-56, Cohere, Dyne-Amic, Bond, Tacktic, and Latron Ag98 (N) No No No Yes